Objectives

The course unit objetives are:

1. Highlight tax topics that corporations operating in an international economic  environment should take into consideration

2. Analyse the instruments or tools ( tax treaties, EU directives, etc) that such companies can use in the tax management of operations

3. Prepare stduents to work on a international tax environment in multinational firms

4. Stressing the importance of taxes in international investment/financing decisions, given the sources of divergence between accounting income and taxable income after the introduction of International Financial Reporting Standards (IFRS) based systems

 

Program and topics

1. Introduction

2. The problem of international double taxation of income in corporate management

3. Methods to avoid double taxation

   • exemption

   • credit

4. The taxation of international groups and dividend repatriation

   • territorial and worldwide tax systems

   • participation exemption regimes

5. Double taxation agreements (DTA) based on the OECD model

   • the tax treatment of: dividends, interest, royalties, capital gains, other income

6. International tax planning and anti-abuse clauses 

   • why do anti abuse clauses exist?

   • how is international tax planning affected by these clauses?

7. Transfer pricing

   • what is the nature of transfer pricing?

   • methods used in transfer pricing

8. The CCCTB and EU tax harmonization

   • a global view of CCCTB

   • does CCCTB have a future?

9. IFRS and corporate tax: recent trends

10. Case studies

 

Classes 

Some classes will center on conceptual issues; others on solving real life case studies in international corporation setting.

 

Evaluation

Multiple choice test

Students can use class materials during tests (slides, cases, notes, etc)

 

Relevance of the course

International tax careers in consulting or management; to pursue masters in International Accounting, Finance or Tax.

 

Bibliography

• Joseph Isenbergh, International Taxation, 3rd (Concepts & Insights), 2009, Foundation Press, N. Y.

• Angharad Miller and Lynne, Oats Principles of International Taxation, 2014, Bloomsbury

• Scholes M.; Mark A. Wolfson; Merle Erickson; Edward L. Maydew; Terry

• Shevlin, 2011, “Taxes and business strategy: a planning approach”, Prentice Hall ed.; Chapters 10 and 11 (Multinational Tax Planning)

• Gravelle J., 2009, “Tax havens: international tax avoidance and evasion”, National Tax Journal, vol LXII, n º4, p. 727-754

• Feinschreiber R, 2004, “Transfer pricing methods”, Wiley and Sons, N. Jersey

• Gee M, et al, 2010, “The influence of tax on IFRS consolidated statements: the convergence of Germany and the UK”, Accounting in Europe, vol 7. P.97-122

• OECD, OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, Paris, July 2010,

 

Instructor

António Martins

Office 501

amartins@fe.uc.pt

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Mais informações

https://apps.uc.pt/courses/PT/unit/80043/12202/2018-2019?type=ram&id=858