MV860K International Tax Law

Faculty of Law
Spring 2019
Extent and Intensity
0/1/0. 5 credit(s). Type of Completion: k (colloquium).
Teacher(s)
Dr hab. Ziemowit Kukulski (lecturer), prof. JUDr. Ing. Michal Radvan, Ph.D. (deputy)
Guaranteed by
prof. JUDr. Ing. Michal Radvan, Ph.D.
Faculty of Law
Contact Person: Mgr. Věra Redrupová, B.A.
Supplier department: Faculty of Law
Timetable of Seminar Groups
MV860K/01: Mon 6. 5. 12:00–13:40 025, 14:00–15:40 025, Thu 9. 5. 10:00–11:40 S126, Fri 10. 5. 8:00–9:40 124, 10:00–11:40 124
Prerequisites (in Czech)
MP702Z Finance Law I || OBOR ( MUS ) || OBOR ( MUSPraF )
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 30 student(s).
Current registration and enrolment status: enrolled: 0/30, only registered: 0/30
fields of study / plans the course is directly associated with
there are 37 fields of study the course is directly associated with, display
Course objectives
At the end of the course students should be able to:
a) understand and explain the differences between double taxation in juridical and economic sense, as well as indicate the means for the elimination of both phenomenons and understand the role and impact of international organizations, such as the OECD, the UN and the EU on the development of international tax law;
b) to work with the information on double taxation conventions on income and capital as well as on other types of tax treaties;
c) to create tax planning policy schemes related with double taxation and its elimination;
d) to make reasoned decision about place of business activity taking into account the exchange of tax information, mutual agreement procedure and assistance in collection of taxes provisions contained in double tax treaties;
e) to make deductions based on acquired knowledge with respect to taxation of business activity, taxation of passive investment income, taxation of realized and non-realized capital gains as well income from employment;
f) to interpret international tax treaties law provisions, courts’ decisions and commentaries to tax treaties.
Syllabus
  • 1. Introduction to the law of international tax treaties
  • 2. Concept of international double taxation and means for its elimination
  • 3. Types of tax treaties in countries’ treaty practice
  • 4. Role of the international organizations (OECD, UN, EU) in the field of development of international tax law
  • 5. Structure, goals, content of the OECD Model Convention on Income and Capital and the UN Model Convention for the Elimination of Double Taxation between Developed and Developing Countries and their impact on countries tax treaty practice
  • 6. Main features of Polish tax treaty practice
  • 7. The Multilateral Instrument (MLI) its impact on the double tax conventions.
Literature
  • See Teacher’s Information for full details
Teaching methods
lectures, discussions
Assessment methods
Written essay
Language of instruction
English
Further comments (probably available only in Czech)
Study Materials
The course is taught only once.
Teacher's information
Literature:

1. Lang M., Introduction to the Law of Double Taxation Conventions, IBFD, 2010

2. Lang M., History of Tax Treaties, IBFD, 2011

3. Lang M., Recent Tax Treaty Developments Around the Globe, Vienna, 2009

4. Maisto G., ax Treaties and Domestic Law, vol. II, IBFD, 2009

5. Shelton N., Interpretation and Application of Tax Treaties, LexisNexis, 2004

6. OECD Model Tax Convention on Income and on Capital. Condensed version 2014 and Key Tax Features of Member Countries 2014, IBFD, 2014

7. Rust A., Double Taxation within the European Union, Wolters Kluwer , 2011

8. Beker P., Double Taxation Conventions, Sweet &Maxwell, 2005

9. Pistone P., The Impact of Community Law on Tax Treaties, Kluwer, 2002

10. Ammatuci A., International Tax Law, Wolters Kluwer, 2012

11. The OECD Multilateral Instrument for Tax Treaties: Analysis and Effects, Edited by Michael Lang, Pasquale Pistone, Alexander Rust , Josef Schuch, Claus Staringer, Wolters Kluwer International 2018.

The course is also listed under the following terms Spring 2017.
  • Enrolment Statistics (recent)
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