International Tax Strategy-F-M-

The first module outlines the basic principles of taxation in national tax laws and in tax treaty law and how these interact. This comprises an overview on the different forms of corporate organization (types of companies) and how these are taxed.

The second module explains the concept of the effective tax rate and provides an overview of how the effective tax rate is impacted by both business decisions and tax planning decisions. In this context, selected tax planning techniques are explained and how they are viewed respectively challenged by tax administrations.

The third module provides an insight into the OECD initiative on base erosion and profit shifting which attempts to redesign the interaction between national and tax treaty law based on the principles of transparency, coherence and substance, in an effort to make tax arbitrage increasingly difficult for MNEs.

The fourth module elaborates on Transfer Pricing as one important tax planning technique and shows along this example how tax administrations interact with taxpayers and the implications of which this has on the organization of the tax department of an MNE from a tax risk management and compliance perspective. Instruments to resolve double taxation, tax controversy and state aid aspects are also covered in this module.

The course addresses students interested in general management positions as well as students with a focus on finance, accounting, investment banking, or strategy consulting.

The aim is to give advanced insights into international tax law (corporate taxation and personal income taxation) and tax planning, and to show how international investment and financing strategies are affected by taxes.

Scholes et al.: Taxes and Business Strategy. A Planning Approach, 5th ed., 2015Miller, Angharad/Oats, Lynne: Principles of International Taxation, 6. Auflage 2017OECD (2017), Model Tax Convention on Income and on Capital: Condensed Version 2017, OECD Publishing.

Lecture and discussion, case studies.

Exam(100%)

Prerequisite: Basic finance knowledge. E.g., NPV, annuity, capital recovery factor. Prerequisite in taxation: none.

150