Eduardo Baistrocchi

This course is available on the LLM (extended part-time), LLM (full-time) and University of Pennsylvania Law School LLM Visiting Students. This course is available with permission as an outside option to students on other programmes where regulations permit.

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

The course has a limited number of places and we cannot guarantee all students will get a place.

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 examines how taxation applies to transactions in the international context. The focus is on rules that operate at an international level, though we will look at some domestic rules that are important to international taxation and that can be found in a number of tax systems. The course will look at a series of international transactions, starting with the very basic example of an export and import of goods and culminating with the treatment of some complex and artificial structures. The features of tax systems will be studied through these transactions, particularly those features found in double tax conventions and in the law of the European Union. In the first part of the course this will be supplemented by introductions to some key foundation concepts that are needed in the study of international taxation. Throughout the course examples will be drawn from the tax systems of a range of G20+ countries and non-G20 tax hubs.

This course will have two hours of teaching content each week in Michaelmas Term, either in the form of a two hour seminar or an online lecture and one hour class. There will be a Reading Week in Week 6 of Michaelmas Term.

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

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 International Tax Regime and the BRIC World: Elements for a Theory (May 10, 2013). Oxford J Legal Studies, May 2013, Available at SSRN: https://ssrn.com/abstract=2336294; 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, reading time: 15 minutes) in the summer exam period.

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