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2020/2021 KAN-CJURV1040U International Taxation of Corporate Groups
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| International Taxation of Corporate Groups |
Course information |
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| Language | English |
| Course ECTS | 7.5 ECTS |
| Type | Elective |
| Level | Full Degree Master |
| Duration | One Semester |
| Start time of the course | Autumn |
| Timetable | Course schedule will be posted at calendar.cbs.dk |
| Study board |
Study Board for BSc/MSc in Business Administration and
Commercial Law, MSc
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| Teaching methods | |
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| Last updated on 10-06-2020 | |
Relevant links |
| Learning objectives | ||||||||||||||||||||||||
| Development of personal competencies:
The overall aim of the course is to enable students to understand and analyze the tax framework regulating the behavior of multinational enterprises (MNEs). The purpose of the course is to provide students the ability to interpret the relevant legal rules and to connect these rules to the facts at hand. In addition, the course should enable students to independently identify nuances in the legal judgment based on the underlying circumstances. Finally, the course aims at providing students with insights into the policy context of the relevant legislation. Goal description: At the highest possible level, the course aims at making students able to identify, analyze, and solve issues of importance for MNEs within the three dimensions of international tax law (internal law, tax treaties, and the EU tax law) while taking account of the rules and principles governing MNE’s international tax planning. Furthermore, the course seeks to enable students to discuss related tax policy issues in an international context at a high level.
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| Course prerequisites | ||||||||||||||||||||||||
| It is recommended that students have followed and passed a basic course in tax law before taking this course. | ||||||||||||||||||||||||
| Prerequisites for registering for the exam (activities during the teaching period) | ||||||||||||||||||||||||
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Number of compulsory
activities which must be approved (see s. 13 of the Programme
Regulations): 1
Compulsory home
assignments
Students are expected to attend the last activity of the course (seminar 9) at which he or she will be expected to actively participate in peer-to-peer feedback: - Give a short presentation of the essay and the findings of the student - Be prepared to give more extensive comments on 3-4 other essays (will be assigned during the course) - Be prepared to take part in general discussions linked to other essays (other than those assigned to the student) |
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| Examination | ||||||||||||||||||||||||
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| Course content, structure and pedagogical approach | ||||||||||||||||||||||||
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In recent years, the tax behavior of MNEs has moved to the very top of the international political agenda. Accordingly, international organizations such as the G20, the OECD and the EU have all been involved in initiatives aimed at mitigating MNEs aggressive tax planning in order to protect national tax bases against base erosion and profit shifting. Moreover, other stakeholders – such as NGOs and the general media – have shown unprecedented interest into the tax matters of MNE’s. As a consequence, it is not sufficient for corporate decision makers and their advisors to only take account of the legislation itself when deciding on tax matters, as perceived amoral tax behavior may cause reputational damage.
Against this background, the course provides a thorough understanding of the legal framework governing cross-border tax issues of relevance for MNEs by discussing the three dimensions of international tax law: 1) internal tax law, 2) tax treaties, and 3) EU tax law. Focus will be on the latter two dimensions. Moreover, the course will provide an insight into the current debate on corporate social responsibility and the policy discussions that influence the tax framework for MNEs. As a red thread throughout the course the student will not only learn tax technicalities referable to these legal sources but also the policy decisions behind them, whether it may be on domestic level, EU level or international level.
The course will focus on the following topics of relevance for MNEs:
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| Description of the teaching methods | ||||||||||||||||||||||||
| To a great extent, the teaching consists of case discussions and discussions based on scientific articles. Active participation is expected from all students during classes – especially in relation to case reviews. It is a prerequisite for participation that students show up well prepared as only parts of the curriculum is reviewed by the traditional lecture method and the rest is employed in relation to cases and discussions of selected issues highlighted in relevant articles. Meanwhile, it is also expected that students have made themselves familiar with the general terms and obtained a basic understanding of daily curriculum before attending. | ||||||||||||||||||||||||
| Feedback during the teaching period | ||||||||||||||||||||||||
| Oral at case discussions in class in addition to
more extensive feedback (during the entire course) in regard of the
individual essay written by the student.
In class the student may expect individual feedback from the teacher at lectures, mainly when working with cases. |
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| Student workload | ||||||||||||||||||||||||
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