MPF_ATAX International Taxation

Faculty of Economics and Administration
Spring 2026
Extent and Intensity
1/2/0. 6 credit(s). Type of Completion: zk (examination).
In-person direct teaching
Teacher(s)
Ing. Radim Procházka (lecturer)
Ing. Petr Valouch, Ph.D. (lecturer)
Guaranteed by
Ing. Petr Valouch, Ph.D.
Department of Finance – Faculty of Economics and Administration
Contact Person: Iva Havlíčková
Supplier department: Department of Finance – Faculty of Economics and Administration
Prerequisites
! MPF_UFII Accounting of financial instit
The course Taxation is a follow-up to the basic courses of accounting. No other special prerequisites are demanded.
Course Enrolment Limitations
The course is only offered to the students of the study fields the course is directly associated with.

The capacity limit for the course is 24 student(s).
Current registration and enrolment status: enrolled: 0/24, only registered: 0/24
fields of study / plans the course is directly associated with
Course objectives
The course focuses on key issues of international taxation of direct taxes, including tax residence, tax jurisdiction, and the taxation of cross-border income. Students will become familiar with European tax law, the OECD and UN Model Conventions, and Double Taxation Treaties (DTA). Emphasis is placed on withholding tax, cross-border tax obligations of both individuals and legal persons, harmonisation within the EU, and rules on social security coordination. The course also covers transfer pricing, tax planning, and anti-BEPS mechanisms, including issues related to the digital economy.
Learning outcomes
Upon successful completion of the course, the student will be able to:

> Analyse and assess the taxation of income based on Double Taxation Treaties (DTAs) – including their relationship to domestic law and the application of double taxation relief methods for both individuals and legal persons.

> Determine the tax residence of a taxpayer and identify tax obligations related to international income – including the assessment of the source of income and applicable tax regime in accordance with Czech and international tax law.

> Identify and apply international social security obligations – determine where the taxpayer must be insured, what contributions apply to foreign-source income, and how coordination rules between EU Member States and third countries function.

> Apply rules on withholding tax and other tax obligations related to the taxation of non-residents – including the analysis of exemptions and limitations under international treaties and domestic legislation.

> Evaluate and properly apply transfer pricing principles – including the arm’s length principle, transfer pricing methods in line with OECD guidelines, and documentation requirements in the area of transfer pricing.

> Critically analyse cross-border tax structures and tax planning strategies – assess the impact of base erosion and profit shifting (BEPS), harmful tax practices, and the implementation of anti-avoidance measures within international tax law.

Syllabus
  • LECTURES:

    (1) Fundamental principles of international tax law, including the concept of tax sovereignty, legal framework of tax residence and tax jurisdiction. Basic taxation models (residence vs. territorial principle) and their application across jurisdictions. Harmonisation of tax law within the European Union and the EEA, the interaction between EU tax law and domestic systems of the Member States. OECD and UN Model Conventions and their influence on national tax policies.

    (2) Cross-border taxation of individuals and their assets. Determination of tax residence and income source. Application of Double Taxation Treaties (DTAs), including double taxation relief methods (exemption and credit methods).

    (3) Coordination of social security systems in the international context. EU regulation on social insurance (Regulations (EC) No 883/2004 and No 987/2009) and social security agreements within the EU. Overview of social security schemes in non-EU/EEA countries and access to benefits under such schemes.

    (4) Key aspects of international taxation of corporations, including the issue of tax residence of legal persons and permanent establishments. Methods for determining the source of income for legal persons and the application of DTAs, particularly in the context of dividends, royalties, and interest. Application of withholding tax on international income within and outside the EU and the tax remitter’s obligations in collecting tax.

    (5) Hybrid mismatches and transfer pricing between associated enterprises. Main transfer pricing methods according to OECD Guidelines, EU regulation, and related documentation requirements. Abuse of law in international taxation, especially in the context of case law of the Court of Justice of the EU. Impact of aggressive tax planning and mechanisms to combat artificial tax structures.

    (6) OECD and EU initiatives aimed at countering aggressive tax planning and base erosion. The BEPS Action Plan and its implementation in various jurisdictions. Taxation of the digital economy, including digital services tax and rules for profit allocation of digital companies. Global minimum tax under Pillar 2 of the BEPS 2.0 initiative and its implications for multinational enterprises.

  • SEMINARS:

    (1) Analysis and interpretation of national tax law in relation to cross-border situations and assessment of instruments forming the framework of international tax law, including Double Taxation Treaties (DTAs) and the OECD and UN Model Conventions. Evaluation of the impact of European law and the case law of the Court of Justice of the EU. The EU Platform for Tax Good Governance and approaches to cross-border taxation in the absence of international treaties.

    (2) Application of DTAs, identification of tax residence, source of income and its taxation, including procedures in the absence of tax treaties.

    (3) Calculation of tax liability on foreign income and determination of worldwide and territorial income, including the preparation of tax returns and the application of double taxation relief methods. Comprehensive case studies.

    (4) Determination of the obligation and territorial scope for social security contributions within and outside the EU. Teleworking within the EU, application of territorial and combined treaties, and procedures in non-treaty states, including administrative practice.

    (5) Solving complex case studies focused on individuals, their rights and obligations regarding taxation and social security. Taxpayer obligations and related penalties.

    (6) Structure of tax treaties related to inheritance and gifts.

    (7) Identification and justification of corporate tax residence, assessment of the existence of a permanent establishment and its effect on withholding tax. Application of EU tax law and DTAs to the taxation of interest, dividends, transfer of shares and royalties.

    (8) Seminar on the application of traditional transactional and profit-based transfer pricing methods in accordance with OECD Guidelines and relevant EU regulations. Emphasis will be placed on the practical use of these methods in determining transfer prices between associated enterprises in line with international standards and EU requirements.

    (9) Application of traditional transactional and profit-based methods using real-world data. Documentation and interpretation of results.

    (10) Identification of hybrid mismatches and their impact on tax liability. Analysis of abuse of law in tax planning and resolution of complex international tax cases.

    (11) Application of anti-avoidance mechanisms and measures to prevent aggressive tax planning. Reporting obligations for cross-border arrangements under DAC6.

    (12) Current approaches to the taxation of the digital economy, including digital services taxes and OECD rules. Analysis of the top-up tax under Pillar Two and its impact on multinational enterprises.

Literature
    required literature
  • KOFLER, Georg W, Michael LANG, Pasquale PISTONE, Alexander RUST and Josef SCHUCH. Exemption method and credit method: the application of article 23 of the OECD model. European and international tax law and policy series. Amsterdam: BFD, 2022. ISBN 978-90-8722-799-9. info
  • LANG, M., G. COTTANI and R. PETRUZZI. Fundamentals of Transfer Pricing: A Practical Guide. Kluwer Law International, 2018. ISBN 978-90-411-8994-3. info
  • HOLMES, Kevin. International tax policy and double tax treaties : an introduction to principles and application. Second revised edition. Amsterdam: IBFD, 2014, xxiv, 432. ISBN 9789087222574. info
  • MAISTO, Guglielmo. Current tax treaty issues: 50th anniversary of the International Tax Group. Amsterdam, The Netherlands: IBFD, 2020. ISBN 978-90-8722-597-1. info
  • Double taxation treaties published in the Collection of Laws and International Treaties
    recommended literature
  • OECD. Pillar One - Amount B: Inclusive Framework on BEPS. OECD/G20 Base Erosion and Profit Shifting Project. Paris: OECD Publishing, 2024. Available from: https://dx.doi.org/10.1787/21ea168b-en. info
  • Hybrid Mismatches After the ATAD in the Czech Republic. Edited by Hrdlička Lukáš. 1. elektronické vydání. Wolters Kluwer, 2022, 1 online. ISBN 9788076765405. URL info
  • OECD. Tax Challenges Arising from Digitalisation of the Economy - Global Anti-Base Erosion Model Rules (Pillar Two): Inclusive Framework on BEPS. Paris: OECDPublishing, 2021. Available from: https://dx.doi.org/10.1787/782bac33-en. info
  • OECD. Tax Challenges Arising from Digitalisation of the Economy - Global Anti-Base Erosion Model Rules (Pillar Two): Inclusive Framework on BEPS. Paris: OECDPublishing, 2021. Available from: https://dx.doi.org/10.1787/782bac33-en. info
  • RADVAN, Michal. Czech Tax Law. 4th ed. Brno: Masaryk University, 2020, 114 pp. Textbook, no. 550. ISBN 978-80-210-9673-8. info
  • OECD. Model Tax Convention on Income and on Capital 2017. Paris: OECD Publishing, 2019. Available from: https://dx.doi.org/10.1787/g2g972ee-en. info
  • OECD. Action Plan on Base Erosion and Profit Shifting. Paris: OECD Publishing, 2013. Available from: https://dx.doi.org/10.1787/9789264202719-en. info
Teaching methods
The course consists of 2 hours of lectures during the first 6 weeks and 2 hours of seminars over 12 weeks. Lectures are delivered in the form of theoretical explanation supplemented by sample problems and practical tax scenarios. Seminars focus on problem-solving and case study analysis.
Assessment methods
The course is completed by successfully passing two mid-term tests. The conditions for successful completion of the course are as follows:

1. Attendance at seminars (maximum of 3 unexcused absences),
2. Active participation in seminars (earning the required number of points),
3. Successful completion of two mid-term tests, each with a maximum of 50 points, with a minimum passing score of 30 points per test.

The final grade is determined by the total number of points from both tests. In order to pass the course, a minimum of 60% must be achieved (at least 60 points out of 100).

If a student reaches at least 60%, points earned for seminar participation (maximum of 12 points) are added to the final score.

Grading scale: A – 92–100% B – 84–91% C – 76–83% D – 68–75% E – 60–67% F – less than 60%
⸻⸻⸻⸻
Mid-term Tests

The first mid-term test takes place during seminar time before the Reading Week. It focuses on the taxation of individuals with foreign income, identification of tax residence, and social security obligations.
The second mid-term test takes place during Week 12, again during the seminar. It covers the taxation of legal persons and their structures, identification of tax residence and permanent establishment, and related reporting obligations. Mid-term tests consist of two comprehensive case studies with theoretical sub-questions.

Test duration: 75 minutes. Maximum score: 50 points. Passing score: 60% (30 points).

Replacement options:
• If a student is excused from a test (with a valid excuse submitted to the study department), they are entitled to a make-up test.
• If a student scores less than 60% in one of the mid-term tests, they are entitled to one retake during the exam period.
⸻⸻⸻⸻
Active Seminar Participation
• Minimum points required for participation to be included in final grade: 6 points
• Maximum points that may be earned for participation: 12 points

Participation scoring:
• Full presentation of a case: 3 points
• Active engagement in discussion: 1 point
⸻⸻⸻⸻
Any cheating, recording or copying of the tests, use of unauthorized aids or communication tools, or any other breach of examination rules will be considered a serious violation of academic regulations. In such cases, the instructor will record a grade of “F” in the Information System and the Dean will initiate disciplinary proceedings, which may result in termination of studies.

Language of instruction
English
Further Comments
The course is taught annually.
The course is taught every week.
The course is also listed under the following terms Spring 2016, Spring 2017, Spring 2018, Spring 2019, Spring 2020, Spring 2021, Spring 2022, Spring 2023, Spring 2024, Spring 2025.
  • Enrolment Statistics (Spring 2026, recent)
  • Permalink: https://is.muni.cz/course/econ/spring2026/MPF_ATAX