Ian Roxan, Room NAB 7.33. Eduardo Baistrocchi is on sabbatical leave Lent Term 2015

This course is available on the MSc in Law and Accounting, Master of Laws and Master of Laws (extended part-time study). This course is available with permission as an outside option to students on other programmes where regulations permit.

This course will be relevant to the following LLM specialisms: International Business Law, Taxation.

This course is capped at 30 students. Students must apply through Graduate Course Choice on LSEforYou.

Students should have at least a basic knowledge of a tax system of a country (not necessarily the UK) or be studying LL4Z1 Business Taxation.

The course will look at a series of international transactions, focusing on the treatment of some complex and artificial structures. They include base erosion, profit shifting and the resolution of transfer pricing disputes. Throughout the course examples will be drawn from the tax systems of a range of countries from the OECD and non-OECD worlds.

20 hours of seminars in the LT. 2 hours of seminars in the ST.

This is based on a format of lecture-discussions with the possibility of guest speakers where appropriate and depending on numbers, corresponding fortnightly one-hour classes.

Students are asked to submit one 2,000 word essay.

Detailed reading lists will be provided during the course via Moodle.

Recommended preliminary reading

Avi-Yonah, Reuven S., 'Double Tax Treaties: An Introduction' (2007). Available at SSRN: http://ssrn.com/abstract=1048441; Baistrocchi, Eduardo A., 'The Use and Interpretation of Tax Treaties in the Emerging World: Theory and Implications' [2008] British Tax Review 352. Available at SSRN: http://ssrn.com/abstract=1273089; Roxan, Ian, 'Limits to Globalisation: Some Implications for Taxation, Tax Policy, and the Developing World' (January 30, 2012). LSE Legal Studies Working Paper No. 3/2012. Available at SSRN: http://ssrn.com/abstract=1995633

Exam (100%, duration: 2 hours) in the main exam period.