Course Outline
Course number
RBE122
Course title
International Tax Law
Credit points
2
Total hours
30
Lecture hours
18
Seminar and other hours
12
Course level
Bachelor
Prerequisites
None
Category
Mandatory
Restricted elective
X
Free elective
COURSE RESPONSIBLE
Name
Barbara Žuromska
Academic degree
LL.M in Law and
Academic position
Lecturer
Finance, Riga Graduate
School of Law (2013)
COURSE TEACHERS
Name
Barbara Žuromska
Academic degree
LL.M in Law and
Academic position
Lecturer
Finance, Riga Graduate
School of Law (2013)
Martins Ozolins
Master of EU Law,
Lecturer
Université de Tours,
France (2004)
COURSE ABSTRACT
The aim of this course is to provide a student with a basic understanding of the international taxation. The
course will outline the principles of taxation both at national and cross-border levels, discover international
environment of taxation and main consideration points for MNEs doing global business around the globe
from the tax perspective.
Upon completion of the course students will have understanding on various tax law sources, namely
international treaties, official documentation from Governmental, and non-Governmental organisations (e.g.
IMF, OECD), as well as European institutions, and tax literature.
COURSE OBJECTIVES
The aim of the course is to introduce the students to international tax law. The primary aim is a
comprehension of the EU and international legal framework, but in some particular topics a closer look will
be taken at specific legislation. The course focuses on developing the problem solving skills of students but
also on giving them a broader and deeper understanding of this area of the law.
GRADING CRITERIA
Criteria
Weighting
Exam
60%
Seminars
30%
Tests
10%
COURSE PLAN – MAIN SUBJECTS
No.
Main subjects
Planned hours
1
Introduction to International Tax Law
4
2
The OECD and the UN Models of Double Taxation Conventions
4
3
International Tax Planning and anti-avoidance measures
8
4
EU Tax Law – Directives, ECJ jurisprudence
6
5
EU principles and policies
6
COURSE PLAN – SESSIONS
Session
Session subjects and readings
Lecture/seminar
1
Core concepts: General overview of taxes in the world economy,
Types of taxes, Taxable persons, Types of income, Taxation
principles
Cross-border Issues: International context, Withholding tax, Double
taxation, Double Tax Treaties
Double tax treaties: Historical background, Presentation of OECD
Model Convention, Definitions of the convention, Elimination of
double taxation
Anti-avoidance measures: General anti-avoidance rules, CFC rules,
Thin capitalization rules, Transfer pricing rules, Tax structures
Transfer Pricing: General overview, value added chain and functional
profile of the business, Arm’s length price, Transfer pricing methods
Application of double tax treaties, identification of taxation issues in
constructed case, application of anti-avoidance measures, practicing
transfer pricing related issues
Discussions on BEPS
Lecture
2
3
4
5
6
7
8
9
EU competence in the field of direct taxation, legislative framework:
 EU or MS competence – delimitation, loss of MS competence
in certain aspects
 Applicable articles of EU Treaties – direct/indirect impact on
direct taxation
 Relations between DTTs and EU tax law – conflicts, priority
of EU law
 Legislation adopted by EU – Parent-Subsidiary Directive, Tax
Merger Directive, Interest and Royalty Directive, Savings
Interest Directive, Administrative Cooperation Directive (direct
taxes), Recovery Assistance Directive, Arbitration
Convention
Case law of ECJ in direct taxation: principles, fiscal restrictions to free
movement of goods and workers:
 Basic principles – residents vs. non-residents, non-
Lecture
Lecture
Lecture
Lecture
Seminar
Seminar
Lecture
Lecture
2
Session
Session subjects and readings
discrimination, non-restriction, permitted restrictions
Steps of analysis of a cross-border tax case –identification of
a problem, applicable law, existence of restriction, existence
of discrimination, possible justification, conclusion
 Free movement of goods – Cases French Newspapers,
Krantz, Keck & Mithouard
 Free movement of workers – rights to tax, possible
restrictions, taxation of pensions, tax credits and allowances,
low income cases
Q & A on the contents of lectures 6 and 7, analysis of a case on fiscal
restrictions to free movement of workers
Case law of ECJ in direct taxation: freedom to provide services,
freedom of establishment, free movement of capital:
 Freedom to provide services – prohibition of discriminatory
tax treatment of service providers and purchasers
 Freedom of establishment – group taxation, exit taxation
 Free movement of capital – tax treatment of investments,
extension to non-EU states
Latest policy developments:
 Measures against harmful tax competition – investigation of
state aid cases, Code of conduct in business taxation,
guidelines
 Fight against tax fraud and evasion – existing tools and future
initiatives
 Draft legislation – CCTB, FTT, amendments to existing
directives
 Policy issues – transfer of tax burden from labour to property,
equal tax treatment of financing by debt and equity, future
challenges
Lecture/seminar

10
11
12
13
Seminar
Lecture
Lecture
Seminar
14
Q & A on the contents of lectures 8 and 9, analysis of a case on fiscal
restrictions to Treaty freedoms, application of EU Directives and
DTTs.
Students’ presentations on known tax cases
15
Revision section
Seminar
Seminar
COURSE LITERATURE
No.
Author, title, publisher
1
Ben J.M.Terra, Peter J.Wattel, European Tax Law
2
Dr Christiana HJI Panayi, European Union Corporate Tax Law
3
Michael Lang, Pasquale Pistone, Josef Schuch, Claus Staringer, Introduction to European
Tax Law: Direct Taxation
4
Isabelle Richelle, Wolfgang Schön, Edoardo Traversa, Allocating Taxing Powers within the
European Union
5
Michael Lang, Pasquale Pistone, Corporate Income Taxation in Europe: The Common
Consolidated Corporate Tax Base (CCCTB) and Third Countries
3