Переосмысление международного налогового права

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.

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.

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.

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.