杏吧论坛

Eduardo Baistrocchi, Room NAB 7.33. 

This course is available on the LLM (extended part-time), LLM (full-time), MSc in Law and Accounting 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.

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 杏吧论坛forYou.

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 G20 countries.

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.

There will be a reading week in week 6.

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

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

Recommended preliminary reading

Baistrocchi, Eduardo, 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; Ring, Diane M., International Tax Relations: Theory and Implications. Tax Law Review, Vol. 60, p. 83, 2007; Boston College Law School Research Paper No. 97. Available at SSRN: https://ssrn.com/abstract=900406; Dharmapala, Dhammika and Hines Jr., James R., Which Countries Become Tax Havens? (May 2009). Available at SSRN: https://ssrn.com/abstract=952721 or http://dx.doi.org/10.2139/ssrn.952721

Exam (100%, duration: 2 hours, reading time: 15 minutes) in the summer exam period.