Course Description

The elective is designed to be an advanced course in direct taxation law. The primary focus is on direct taxation and double taxation avoidance agreements. The elective introduces students to the fundamentals and key conundrums within international taxation which is a niche area.

Application of international tax law requires knowledge of domestic tax law. This course will thus also deepen the knowledge of domestic tax law with respect to the cross-border aspects (such as residence, source, fees for technical services and business connection).

Each session (or set of sessions) takes up a different fundamental and topical issue. The readings for each session are prefaced with a few lines / questions so that students can adequately reflect on the readings prior to class. It is hoped that this will facilitate deeper engagement with the materials as the elective depends on sustained student participation. The delivery of the course will combine lectures and seminars involving students trying to solve case studies of cross-border tax controversies.

The materials used in the course is a mix of scholarly literature, case law, text and commentaries of the OECD and UN Model Convention. As it is an advanced course, students are encouraged to read through the recommended textbooks alongside the different sessions. Some sessions also provide for a longer list of recommended additional readings.