Eduardo Baistrocchi, CKK 7.33

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: Competition and Innovation, Public International Law, International Business Law, and Taxation.

The course is capped at 30 students. Students must apply through Graduate Course Choice on LSE for You.

The course offers a comprehensive introduction to international taxation. It examines how taxation applies to transactions in the international context. The focus is on rules that operate at a global level, particularly the OECD Model Tax Convention on Income and on Capital, which is the basis of over 3,500 bilateral tax treaties worldwide. The course will look at a series of cross-border transactions, starting with the basic example of export and import of goods and culminating with the treatment of some complex and artificial structures. The features of the international tax system will be studied through these transactions, particularly those found in double tax conventions and the law of the European Union. This approach will be supplemented by an analysis of some foundation concepts needed to study international taxation. Throughout the course, examples will be drawn from the tax systems of a range of jurisdictions, including G20 countries and tax hubs.

20 hours of seminars in the AT and 2 hours of seminars in the ST.

This module is based on a lecture-discussion format with the possibility of guest speakers where appropriate. Students in this course will have a reading week in Week 6, which aligns with law school policy.

Students will have the option of producing a formative essay of 2,000 words.

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

Eduardo Baistrocchi, ‘Global Tax Hubs’, Florida Tax Review (2024) Available at SSRN: https://ssrn.com/abstract=4544786; 

Eduardo Baistrocchi, ‘The International Tax Regime and Global Power Shifts’,  Virginia Tax Review, Vol. 20, No. 2, 2021, Available at SSRN: https://ssrn.com/abstract=3744992; 

Eduardo Baistrocchi, ‘The International Tax Regime and the BRIC World: Elements for a Theory’ (2013). Oxford J Legal Studies, Available at SSRN: https://ssrn.com/abstract=2336294;

Edward Kleinbard, ‘Stateless Income’ (2011). Florida Tax Review, Vol. 11, p. 699, 2011, Available at SSRN: https://ssrn.com/abstract=1791769;

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 and 30 minutes) in the spring exam period.