This class exists in these courses :
• IÉSEG > IESEG Degree - Programme Grande École > Semester 2 > 2,00 ECTS

Prerequisites

The prerequisites are a good capacity to understand international complexity and laws interaction. International tax obliges to have a national focus on rules in a world of consolidated accounts and to understand the articulation between the consolidated point of view and the impact of national rules and practices . A minimum of legal knowledge and capacity to analyse legal concepts is also important to acknowledge the potential legal impact which may vary from one country to another because of the diversity of domestic legal organisations, rules and sensitivity. Also a worldwide vision is necessary to analyse the major trends in international field and the role of major international organisations such as OECD, UN and EU .

Learning outcomes

At the end of the course, the students should be able to:
Upon successful completion of the course, the student will gain knowledge and technical skills related to:
- Basic international tax concepts and tax rules governing Transfer Pricing, Permanent Establishment, Uncertain Tax Positions, VAT and Corporate Taxes.
- The design of international tax planning within multinational corporations consistently with strategies and organizational choices.
- The use of transfer prices in managing business units of multinational companies.
- Understanding of the complexity and hierarchy of international tax rules as well as the concept of Soft Law. - Students will be aware of the vast changes which are ongoing worldwide in the field of international tax requirinig more transparency and the fight from international organizations against aggressive tax practices.
- Basic knowledge of territorial and worldwide tax systems as well as The Tax Cuts and Jobs Act (TCJA).
- Basic knowledge of the major tax cases which are at stake between the European Union and the United states as well as the role of a Tax Director in a multinational corporation.

Course description

Review of major tax international key concepts and major focus on Transfer pricing, Permanent Establishment and Uncertain Tax Positions; including a case study .
Brief presentation of the VAT system (scope, territotial rules).
Brief presentation of the territorial vs. worldwide system of taxation and the impact of the The Tax Cuts and Jobs Act (TCJA) on it.
Description of major trends at the international level which aim to reform the existing international tax rules such as the BEPS (Base Erosion and Profit Shifting) initiative lead by OECD and associated consequences.
Conclusion on the positionning of the Tax Director in an international company and the definition of what can be a Tax Governance

Class type

Class structure

Teaching methods

• Case study
• E-learning
• Interactive class
• Presentation
• Project work
• Tutorial

Assessment

Each session shall be introduced by a short case study prepared by student's group. The Course will be performed trying to be as interactive as possible. The final examination will take the appropriate form ensuring the effective understanding of the basics (case study ,short questions, limited Q&A)

Class participation does not mean attendance, which is assumed. Class participation means qualitative contribution to class discussion (i.e. the ability to answer the teacher’s questions, to add new dimensions to the discussion, to critically examine cases and theory topics, to provide real-life examples). In any case, it is a requirement of this course that you read and prepare the assigned cases prior to attending class according to the questions reported on the course website.

Recommended reading

• Selected chapters from Taxes and Business Strategy – A planning approach (Scholes et al.) ISBN-13: 978-1292065571 -

Internet resources

• OECD

• Official website of the European Union

• IBFD

• IESEG Online