International Tax Law

DESCRIPTION

Students will be given the opportunity to attend some classes from the Master of Advanced Studies in International Taxation at the University of Lausanne (MASIT). The MASIT offers high-level education in tax law, bridging a policy and practical oriented approach. The programme takes into account latest international tax policy developments in the post-BEPS world, in particular:

• Most recent tax treaty and transfer pricing policy developments and their impact for MNE groups;
• Core tax treaty disputes and the evolution of dispute resolution mechanisms;
• Taxation in light of the digitalisation of the economy;
• Most recent tax policy developments in the European Union, including the relationship among Member States and third countries.

International Tax Law course is composed of International Tax Policy and Advanced Issues in International & European Tax Law courses.

International Tax Policy aims at exploring international tax policy in a holistic fashion and, to that end, bridges its legal, strategic and political dimensions. In particular, the course discusses how international consensus is negotiated and formed at the level for example of the G20, the OECD and the Inclusive Framework. The course also looks at the dynamics of international tax policy, such as the public’s perception, the political and economic context as well as the role of elements such as “tax morale” and reputational risks triggered by taxes and the impact of these elements on corporate tax governance.

Advanced Issues in International & European Tax Law, on the other hand, discusses, at a more advanced level, selected important topics traditionally at stake in international tax disputes and controversies. The course takes a holistic approach and explores the relevance of certain non-tax instruments as well as other areas of public international law in cross-border tax disputes. Accordingly, the role played by bilateral investment Treaties (BITs) and their interaction with domestic tax measures, double taxation conventions (DTCs) and avenues for dispute resolution are discussed. Moreover, the broader framework of public international law governing the compliance by States with their international tax obligations is examined. All issues presented will be illustrated by multiple case studies and leading decisions rendered by courts in Switzerland, in Europe and around the globe.