Singapore University of Social Sciences

Tax Planning and International Taxation

Tax Planning and International Taxation (TAX507)

Synopsis

TAX507 International Tax and Tax Planning equips the student with the knowledge of the bases of international taxation; both the hard-law of tax treaties to the soft-law of general principles that have arisen over time. It introduces the student to various planning principles, ideas and opportunities that exist for the cross-border business. It is primarily a course that introduces students to International Taxation matters covered in far greater depth in later MTax courses. Globalisation means that increasingly more businesses are being conducted across borders. These new business ventures provide opportunities for large and small enterprises to look for new markets. However, venturing to do business across a border could result in unexpected tax bills, and could render what would have been a good venture into an unmitigated disaster. This course provides the students with an overview of such international tax matters and examines pre-BEPS and post-BEPS ideas. (BEPS refers to the Base Erosion and Profit Shifting project undertaken by the OECD/G20 nations in 2012 to reform the international tax system because of perceived tax planning abuses.)

Level: 5
Credit Units: 5
Presentation Pattern: Every January

Topics

  • Fundamental Concepts in International Taxation
  • Nexus
  • Permanent Establishments
  • Tax Treaties
  • Fundamental Objectives in International Tax Planning
  • Business Aims
  • Fiscal Aims
  • Anti-avoidance Attacks
  • Major themes in International Tax Structuring
  • Holding Company Regimes
  • Tax Effective Supply Chain Restructurings
  • Base Erosion and Profits Shifting
  • Anti-avoidance Measures
  • Pre-BEPS measures / BEPS measures
  • Transfer Pricing
  • Controlled Foreign Companies

Learning Outcome

  • Evaluate the facts in various case-study scenarios, and correctly identify the taxation issue presented
  • Assemble all sources of law and practice relevant to the issue identified
  • Critically appraise the various authorities that may exist in this area, be they case law, statute law etc.
  • Distinguish precedent cases from fact pattern presented
  • Formulate a position paper, strategy document or tax advice on matters relating to the taxation issue
  • Examine and analyse legal materials which are written in technical or complex language
  • Discuss through different forms of communication, such as verbal, written and formal presentations, presenting knowledge or an argument in a way which is comprehensible to others
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