Subjects 2009
Tax Treaties 730773
- Credited Courses: Graduate Diploma in International Tax 191; Graduate Diploma in Tax 187; Master of Commercial Law 504; Master of International Tax 192; Master of Laws (LLM) 502; Master of Tax 742
Objectives
This subject provides an in-depth examination of international tax treaties, both as regards inbound and outbound investment, using the OECD Model Treaty and commentary and including an examination of important treaties of Australia and its major trading partners. It examines current issues of international taxation in the application and interpretation of tax treaties, including the meaning of permanent establishment and taxation of business profits; residence and source; the treatment of investment income; exchange of information and avoidance of double taxation. Upon successful completion of this subject, students should have an advanced understanding of the policies in relation to tax treaties.
Syllabus
Principal topics will include:
- Principles of double tax treaties
- Interpretation of tax treaties
- Relationship between tax treaties and domestic law
- Impact of tax treaties on investing into Australia
- Impact of tax treaties on investing overseas
- Entities and tax treaties
- Tax treaties and tax avoidance.
