|Teacher/Coordinator: Prof Michael Dirkis|
Classes: 1x2-hr lecture/week. NB: The first class will commence on Thursday 1 March.
Assessment: 3000wd assignment (30%) and 2hr exam (70%)
|Australian International Taxation is a detailed study of the fundamental principles of Australia's international taxation regime as it applies to cross-border business and investment transactions. The unit focuses on corporate residence, source, non-resident withholding tax, relief from international double taxation, CFCs, transferor trusts, proposed new Foreign Accumulation Fund ("FAF") regime and repealed FIF rules, transfer pricing and thin capitalisation. The unit will examine both the issues of international tax rule design and policy, and the relevant provisions in the legislation, cases and rulings. The unit deals only with international tax rules in Australia's domestic law with double tax treaties covered in the companion unit Tax Treaties. Students should gain an understanding of the policies underlying Australia's rules for taxing international transactions, as well as a detailed knowledge of the foundation principles of law applicable to the taxation of inbound and outbound transactions.|