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2023/2024 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 |
| Max. participants | 20 |
| Study board |
Study Board for BSc/MSc in Business Administration and
Commercial Law, MSc
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| Course coordinator | |
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| Teaching methods | |
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| Last updated on 11-09-2023 | |
Relevant links |
| Learning objectives | ||||||||||||||||||||||||||
| Development of personal competencies:
The overall aim of the course is to enable students to understand and (critically) 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 (critically) discuss related tax policy issues in an international and societal context.
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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. However, it is not mandatory. The course is open to students from various disciplines outside of traditional tax scholarship, e.g. sociology, economics etc. | ||||||||||||||||||||||||||
| Examination | ||||||||||||||||||||||||||
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| Course content, structure and pedagogical approach | ||||||||||||||||||||||||||
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In recent years, the tax behavior of multinational enterprises (MNEs) has moved to the very top of the international political agenda. As a response, 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 (BEPS). 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 but also fiscal policies and current political discouses.
Against this background, the course provides a thorough understanding of the legal framework and fiscal policies 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.
Moreover, the course provides insights into the current debate on corporate social responsibility, the relationship between the global south and the global north, 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. A critical perpsective is applied to the entire course, enabling students to achieve a broader understanding of taxation and fiscal policy than traditionally offered by tax (technical) courses.
The course will focus on the following topics of relevance for MNEs:
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| Description of the teaching methods | ||||||||||||||||||||||||||
| In fall 2023 the course will be taught as a Study
Group.
To a great extent, the teaching consists of case discussions and discussions based on scientific articles. Active participation is expected from all students during these classes. Therefore, it is a prerequisite 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 essay writing and subsequent supervision. It is expected that students have made themselves familiar with the general terms and obtained a basic understanding of daily curriculum before attending. Course coordinator provides instructions for this preparation, e.g. reading material + what discussion questions to prepare. For the students without prior experience of legal courses or tax law in general: There is a guide with reading material which you may ask course coordinastor of before the start in order to prepare yourself. |
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| Feedback during the teaching period | ||||||||||||||||||||||||||
| Oral discussions in class during lectures in
addition to more extensive feedback (during the entire course) in
regard of the individual chosen topic.
Additionally, all students will participate in peer-grade activity and, as a result, provide each other with feedback on the individual topic as they are progressing. |
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| Student workload | ||||||||||||||||||||||||||
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