INTERNATIONAL TAXATION
Année du cours : 1 année(s)
Etablissement : IÉSEG School of Management
Langue : English
Formation(s) dans laquelle/lesquelles le cours apparait :
Période : S2
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 .
Have a clear knowledge of the basic international tax concepts and international rules governing both VAT and Direct Corporate Taxes. One should be able to understand the complexity and hierarchy of international rules as well as the concept of Soft Law. Students have a basic understanding of conventional treaties and their major definition such as “Permanent establishment”: Students become aware of the vast changes which are ongoing worldwide in the field of international tax requirinig more transparency and fight against aggressive tax practices and should understand the major tax cases which are at stake between the European Union and the United states. Finally he should have a better vision of what is the exact role of a Tax Director in an international company’s organisation and the interaction with other finance functions.
Review of major international key concepts and major focus on Permanent Establishment; including a case study .
A comprehensive presentation of the VAT system (scope, territotial rules, complience requirement)
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 .
Content of the international reforming planning and major challenges between tax harmonization and national sovereignty.
Conclusion on the positionning of the Tax Director in an international company and the definition of what can be a Tax Governance
