Subjects 2009
International Taxation: Principles and Structure (formerly Australian International Taxation) 730606
- Credited Courses: Graduate Diploma in International Law 323; Graduate Diploma in International Tax 191; Graduate Diploma in Tax 187; Graduate Diploma in Transnational Law 333; Master of Commercial Law 504; Master of International Tax 192; Master of Laws (LLM) 502; Master of Laws (LLM) 502; Master of Public and International Law 511; Master of Tax 742
Objectives
A student who has successfully completed this subject should:
- Have an advanced understanding of the policies underlying Australia’s rules for taxing international transactions
- Have a detailed knowledge ofthe foundational principles of law applicable to the taxation of inbound and outbound transactions.
Syllabus
This subject is designed to explore in detail the fundamental principles of Australia’s international taxation regime. It will examine both the issues of tax design and policy, and the relevant provision in the legislation, cases and rulings.
Principal topics will include:
- Principles of international taxation
- Rules for determining residence and source
- Domestic rules for the taxation of residents’ foreign income (foreign tax credit, accruals taxation of foreign income and exemption of foreign income)
- Domestic rules for the taxation of non-residents’ Australian source income (interest, dividends, royalties and business profits)
- Introduction to tax treaties
- Introduction to thin capitalisation rules.
