Digitalization, and the new business models that have emerged as a result, have underlined the existing inefficiencies and limitations of the tax system, including the difficulty to capture significant digital activities that do not require any physical presence and the need to tax super-profits mainly related to valuable intangible assets located in low or no tax jurisdictions. More importantly, the global call for a substantial reform of the tax system has brought together many nations and their varied approaches to taxation, raising questions of fairness, global wealth distribution and sustainability. In this context, new approaches to global tax governance have also emerged, in particular the inclusion of various multilateral instruments and agreements on top of a complex network of bilateral tax treaties.
Against this background, the module covers the challenges that technology has brought to international and domestic tax systems and the policy solutions that countries and international organizations developed as a response to these challenges. Emphasis will be put on identifying different perspectives (taxpayers, policymakers, legal advisors), developing a critical understanding of opposing interests, as well as conceptualizing how these might differ depending on the socio-economic characteristics of the countries involved (developing, developed and emerging economies) and ultimately shape international tax policy.
Throughout the module, examples will be provided from different jurisdictions (case law and domestic provisions) to explain tax concepts and different policy approaches, and case studies will be used to clarify corporate structures, value creation processes and tax policy implications. These examples and case studies should allow students to apply theoretical knowledge to real life problems and demonstrate a critical understanding of the syllabus.
This module will be taught intensively over a period of one week in Semester 3.
3,000-4,000 word essay
15 Credits