Rethinking International Tax Law
Universiteit Leiden
Acerca de este Curso
In recent years, the international tax planning strategies of multinationals have become a source of – often heated – debate. This course provides learners with the tools to become fully informed participants in the debate by explaining the foundations and practice of international tax law as well as addressing current developments and the ethical aspects of tax planning.
Syllabus - What you will learn from this course
1
Section
International tax planning – base case
In this first week, we will start on our journey into the world of international taxation. We will see that the tax planning activities of multinationals have attracted a lot of attention during the past few years. We will examine why planning strategies are now in the public eye, what the public debate is really about and who the key players are. We will also go to the core of international tax planning and build a base case, the elements of which we will study throughout the course.
8 videos (Total 48 min), 16 readings, 3 quizzes
8 videos
The Debate6m
Background & key stakeholders5m
The OECD & the EU5m
Introduction base case8m
Optional: Introduction to symbols2m
Interview: Prof. dr. Kees van Raad7m
Introduction to BEPS7m
16 readings
Meet the instructor & his team !5m
Course Syllabus5m
How to pass this course & obtain your certificate5m
Welcome to Leiden University5m
Complete our short survey10m
Tips for studying online5m
Being successful in an international virtual learning community5m
Behaving in an academic way5m
Optional: Recording - Public Accounts Committee hearing on taxation of multinational corporations10m
Resources: Media on the international tax planning debate0m
Required reading30m
Recommended reading0m
Required reading30m
Database BEPS10m
Video transcripts - module 110m
OECD & UN model tax conventions0m
2 practice exercises
Exercise 12m
Base Case20m
2
Section
Design of corporate tax law systems
In this second module, we will start breaking down our tax planning base case. To that end, we will study the design of corporate tax law systems during this module. In the videos and (recommended) reading materials, we analyse the typical design elements of corporate tax law systems.
8 videos (Total 45 min), 5 readings, 4 quizzes
8 videos
Taxable base & rate6m
Taxable base & rate: tax havens & preferential tax regimes4m
Taxable base & rate: intercompany dividends & capital gains4m
Taxation of corporate groups5m
Withholding Tax5m
Interview prof. dr. Kees van Raad4m
Advanced Track: Interest deductions and other financial payments6m
5 readings
Required Reading30m
Required Reading30m
Recommended Reading0m
Video transcripts - module 230m
Optional: Local country corporate tax features survey30m
4 practice exercises
Exercises 1-36m
Exercise 42m
Exercise 52m
Design of corporate tax law systems20m
3
Section
Principles of international taxation & tax treaties
In this third module, we will continue to analyze our tax planning base case. To that end, in module 2, we studied the typical design of corporate tax law systems. In this module, we will look at international aspects of corporate tax law systems (CFC, qualification mismatches). We will also get to the core of international tax law and study double tax treaties.
8 videos (Total 63 min), 7 readings, 4 quizzes
8 videos
Hybrid mismatches10m
Introduction to international tax law5m
Double taxation8m
Distributive rules11m
OECD & BEPS5m
Interview prof. dr. Kees van Raad7m
Advanced Track: Hybrid mismatch arrangements & preventing treaty abuse8m
7 readings
Recommended reading0m
Recommended reading0m
Required reading30m
Optional: OECD BEPS Project - 2013 Initial Report and 2015 Final Reports0m
Recommended reading0m
Required reading30m
Video transcripts - module 330m
3 practice exercises
Exercise 12m
Exercise 22m
Principles of international taxation & tax treaties20m
4
Section
Transfer pricing
In this fourth module, we will be focusing on transfer pricing, a technique which is used to allocate the profits made by a group of companies to the individual group members. Transfer pricing is an area of tax law which is becoming increasingly important. Our study will focus on the basics of transfer pricing: the 'arm's length principle', comparability and transfer pricing methods, but will also address business restructurings and include a case study.
10 videos (Total 53 min), 8 readings, 3 quizzes
10 videos
Introduction to transfer pricing and why it is important4m
The arm’s length principle: legal framework5m
Traditional transaction methods5m
Transactional profit methods5m
Business restructuring6m
Apple case7m
Outro - Transfer Pricing1m
Interview Prof. Dr. Kees van Raad8m
Advanced Track - Transfer pricing of intangibles5m
8 readings
Required reading30m
Recommended reading0m
Recommended reading30m
Required reading30m
Recommended reading30m
Recommended reading30m
Required reading30m
Video transcripts - module 430m
3 practice exercises
Exercise 12m
Exercise 22m
Transfer pricing20m
5
Section
European Union law & fiscal state aid
In this fifth module, we will take a look at the developments in the area of corporate tax planning within the EU, focusing on recent developments and the actions which have been taken within the EU to ensure that international tax planning of multinationals does not negatively affect corporate taxation within its territory. Also, we will discuss the limits which EU tax law places on domestic and international measures to counter aggressive tax planning and BEPS.
9 videos (Total 63 min), 5 readings, 3 quizzes
9 videos
Tax competition & tax planning6m
Introduction to state aid law6m
State aid & tax planning6m
Adjustment P/S Directive6m
EU Free Movement Law (I)5m
EU Free Movement Law (II)7m
Interview Prof. Dr. Kees van Raad6m
Advanced track - Draft Commission notice on the notion of state aid8m
5 readings
Required reading30m
Required reading30m
Required reading30m
Recommended reading0m
Video transcripts - module 530m
2 practice exercises
Exercise 12m
European Union law & fiscal state aid20m
6
Section
Tax planning & ethical dimensions
This sixth and last module will be about the ethical aspects of tax planning. Prof. Douma will be interviewing a number of key stakeholders in the current debate to reflect on what we have learned in the previous modules. In addition, you will find the final exam which will enable you to complete the course.
11 videos (Total 83 min), 7 readings, 2 quizzes
11 videos
Interview Pascal Saint-Amans8m
Interview Marlies de Ruiter6m
Interview Paul Morton7m
Interview Antonio Russo9m
Interview Tanja Bender6m
Interview Robert Stack12m
Interview Giuseppe van der Helm13m
Interview prof. dr. Kees van Raad8m
Outro - tax planning & ethical dimensions1m
Advanced Track - BEPS & developing countries5m
7 readings
Required reading30m
Optional: pre week 6 survey5m
Optional: post week 6 survey5m
Required reading30m
Recommended reading0m
Video transcripts - module 630m
Complete our short survey10m
2 practice exercises
Tax planning & ethical dimensions20m
Final exam0m
4.8
57%
83%
17%
Top Reviews
By PC•Feb 14th 2018
Very Comprehensive Training.\n\nPresentation is well structured and clear, from general overview to very technical topics\n\nVery helpful to get a sound knowledge about International Tax Matters.
By LS•Mar 17th 2018
This course is very interesting and very well done. Video are very interesting and educational. I highly recommend this course to everyone who want to learn some of the international tax system.
Instructor
Prof. Dr. Sjoerd Douma
Faculty of LawAbout Universiteit Leiden
Leiden University is one of Europe's foremost research universities. This prominent position gives our graduates a leading edge in applying for academic posts and for functions outside academia.
Leiden University is the oldest university in the Netherlands. It was founded in February 1575, as a gift from William of Orange to the citizens of Leiden after they had withstood a long siege by the Spanish. Our motto is: Praesidium Libertatis — Bastion of Liberty.
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