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Comparative Corporate Tax

Elective


The Comparative Corporate Tax course considers the basic elements of corporate tax systems in a structural setting. The focus is on three artificialities that arise from the nature of a corporation: the artificiality of a corporation as an income deriving entity; the artificiality of a corporation as a source of income in the form of dividends; and the artificiality of shares in corporations as assets separate from the assets held by a corporation. The course focuses on the corporate income tax systems of Australia, Germany, the UK and the US. The course does not deal with generic income tax issues (applicable to both individuals and corporations), such as the calculation of business income.

The course includes the following topics:

  • Derivation: identifying corporations, group taxation, tax treatment
  • Distribution: debt/equity distinction, hidden profit distributions, dividend relief
  • Incorporation, transfer of shares, change of control
  • Return of capital, share buy-backs, liquidation
  • Bonus shares, convertibles, options, reconstructions, mergers, demergers

The course is taught by Professor Peter Harris, University of Cambridge and Professor John Vella 

Optional for these programmes: MSc in Taxation (Part Time)

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Current Issues in Taxation

Elective


The Current Issues in Taxation course will explore issues of topical importance in the field of taxation. The content will vary from year-to-year, and the course will be taught primarily by visiting lecturers, with contributions from Oxford-based academics.

In 2020-21, the course will be Current Perspectives on Classic Texts in Tax Law & Policy

Tax law is at a crossroads. Dramatic changes over the past years on the national, regional, and global levels have yielded substantial challenges for tax law and policy. These changes have brought to the forefront big questions on the normative and practical levels, domestically and internationally. Classic dilemmas of increasing welfare versus (re)distributing it have intensified, while new dilemmas of membership in democratic societies, tax competition, and international cooperation have emerged.

In this course we will go back to some of the most influential articles, books, reports and cases on various aspects of tax law and policy (e.g., what is income, tax and inequality, tax expenditures, taxing women, competition v. cooperation and global justice). We will read these classics with a critical eye, evaluate their contributions, confront them with their critics, and examine their relevance to contemporary times and the issues currently at stake. 

The course will employ a variety of normative considerations – justice, efficiency, personhood and democratic participation – and will engage with methods and concepts that often inform other areas of law as well as other disciplines, but no prior knowledge of any of the above is required.

The course will be taught by Professor Tsilly Dagan with guest lecturers Linda Sugin, Fordham Law School, Reuven Avi-Yoanh, University of Michigan School of Law and others.

Optional for these programmes: MSc in Taxation (Part Time)

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Dissertation

Where a student can show evidence that he or she is capable of a long dissertation of 12,000 words and wishes to submit such a long dissertation, this may replace two of the electives, subject to agreement on a topic by an MSc in Taxation course director which will depend on an assessment of the student's capacity to produce a long piece of written work and whether a suitable topic and supervisor can be found. A course director must be satisfied that the dissertation topic is of sufficient scope and depth to be appropriate to replace two courses. The director shall make the decision in consultation with the other directors.

The long dissertation may cover material not covered expressly by any other course on the programme or may build on material covered in another course within the programme provided it has the necessary element of originality, analysis and independent research.  A teacher on the MSc in Taxation must have the suitable knowledge to supervise the dissertation before it can be accepted as an appropriate topic. The topic must, however, be sufficiently different from that chosen for the Tax Research Round Table extended essay to avoid overlap and unfair reduction of burden. It may not be a dissertation, or part of a dissertation, that has been or is being submitted for any other degree in Oxford or elsewhere.

The demand for supervision for such dissertations may exceed the supply, especially from particular Faculty members, and where this is the case, a potential supervisor may elect to supervise only those dissertations which he or she judges most promising. Although in principle the option of offering a dissertation is open to all Taxation students, therefore, in practice, it is possible that some students who wish to offer a dissertation will be unable to do so, as a suitable supervisor with spare capacity cannot be found. 

Optional for these programmes: MSc in Taxation (Part Time)

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Ethical Issues in Tax Practice

Elective


The Ethical Issues in Tax Practice course focuses on some of the ethical issues that arise for those involved in the tax world, whether as tax advisors, in-house tax counsel, tax officials, or tax policy makers. The emphasis is on the classroom discussion of several scenarios that raise ethical issues.  Guests are invited to the class to speak on related issues, including corporate social responsibility, and on the limits of acceptable tax avoidance. It is an opportunity for tax professionals (or potential tax professionals) to work through and think through some of the potential ethical issues they will face (or may already have faced) in practice.

The course is taught by Visiting Professor Philip Baker QC, Professor Judith Freedman and others. 

Optional for these programmes: MSc in Taxation (Part Time)

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EU Tax Law

Elective


The course EU Tax Law will enable students to develop an in-depth understanding of European Union (EU) tax law and policy in the global context. This course will provide a comprehensive overview of the key aspects necessary for understanding how EU law affects investors and other economically active persons and entities within the EU and from third countries; as well as demonstrating how the EU’s tax policies are influenced by and shape global tax developments.

The programme will include the study of:

•The primary law of the European Union and the effects it has on Member States’ direct taxation through the fundamental freedoms. This part will focus on landmark cases and several case studies which illustrate the impact of EU law on national tax systems, including exit taxation and anti-avoidance cases. Both the examples of the application of the freedoms within the territory of the EU/EEA and in third-country scenarios will be addressed. 

•The interaction between the international and European legal order in the tax context. The relationship between various types of legal instruments will be covered, including possible tensions between the Anti-Avoidance Directive and bilateral tax treaties and the application of the OECD’s Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting in the EU.

•EU fiscal state aid. This part will offer an overview of fundamental features of the EU fiscal state aid regime, its impact on tax rulings by EU Member States and an in-depth inquiry into the Apple case.

•The EU secondary legislation which facilitates cross-border capital flows (the Parent-Subsidiary Directive and the Interest and Royalties Directive), tackles abusive tax practices (the Anti-Avoidance Directive), stimulates administrative cooperation (the Directives on Administrative Cooperation in Tax Matters) and introduces an obligation on Member States to arrive at a resolution of all disputes that originate in bilateral tax treaties (Directive on Tax Dispute Resolution) will be discussed.

•Non-binding measures (the so-called “soft law”), including those aimed at tackling “harmful tax competition” and the promotion of good tax governance in third countries through the “black” and “grey” lists of non-cooperative jurisdictions. 

•Current issues in EU tax law and ongoing policy work, including the proposed harmonisation of corporate tax base and the introduction of formulary apportionment (Directive on Common Consolidated Corporate Tax Base), and the initiative on the taxation of the digitalised economy.

The course is taught by Dr Anzhela Cédelle, Oxford University Centre for Business Taxation and others.

Optional for these programmes: MSc in Taxation (Part Time)

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Principles of International Taxation

Core Course


The Principles of International Taxation core course introduces students to international taxation. It is also a foundation course for subsequent international tax courses.

The course includes the following topics:

  • Introduction to international tax law and state practice in claiming tax jurisdiction
  • History of international tax law
  • Principles for taxing international business income
  • Causes of international double taxation and methods of relief
  • Introduction to tax treaties, and the OECD Model Tax Convention
  • Transnational enforcement of tax liabilities
  • Settlement of international fiscal disputes
  • Tax havens, harmful tax competition and cooperation amongst revenue authorities
  • The future of international tax law

The course is taught by Visiting Professor Philip Baker QC, Professor Tsilly Dagan, Professor Michael Devereux and Professor John Vella

Compulsory for these programmes: MSc in Taxation (Part Time)

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Tax and Public Policy

Elective


The Tax and Public Policy course provides students with the essential tools to assess tax policy, with a particular emphasis on economic analysis. After discussing where economic analysis fits in the complete toolbox for assessing tax policy, students will be taught the essential tools from economic analysis in some detail. Having equipped students with these tools, the course then guides them through some fundamental issues in tax policy design. A number of cases studies are using during the course.

This is an elective course. Issues of tax policy will be considered in other compulsory and elective courses on the MSc. However, this course will cover these various issues in tax policy in a coherent and more detailed manner and with a greater emphasis on economic analysis.  

The course includes the following topics:

  • Tax Design and the Complete Toolbox
  • Economic Tools and /Concepts (including efficiency and optimal tax theory)
  • Some Fundamental Tax Policy Choices (including tax base, taxation of capital, rents)
  • Corporation Tax Policy

The course is taught by Professor Michael Devereux and Professor John Vella 

Optional for these programmes: MSc in Taxation (Part Time)

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Tax Principles and Policy

Core Course


Tax Principles and Policy

This core course introduces students to fundamental principles in taxation as well as enabling students to meet with each other and exchange ideas.  Students taking this degree come from a variety of disciplinary backgrounds and have varying levels of experience, but all will have something to learn and something to bring to the table during this interactive course.

The focus is on themes and concepts that will provide students with the necessary grounding to study a range of topics in tax law within their political and economic context. The aim is to create an understanding of the requirements of a tax system and the difficulties encountered in designing, legislating for and administering such a system.

The course includes the following topics:

  • Tax Concepts (including objectives and function of tax, tax base, capital vs income distinction in tax law, relationship between tax and accounting profits, sources of tax law and constitutional issues)
  • The Tax Unit (individuals, couples or families? Taxing companies, partnerships, trusts and other entities)
  • Tax Avoidance (including the meaning of tax avoidance, and judicial and legislative responses)

The aim of the course is to provide students with a common foundation of key principles, concepts and policy issues in tax. Students will be able to draw upon their understanding of these principles, concepts and issues, including the objectives of tax and tax avoidance, in developing their understanding of the material covered on their other compulsory and optional courses.

The course is taught by Professor Judith Freedman and Professor Glen Loutzenhiser with contributions from Professor Michael Devereux and Professor John Vella.

*Note: Course content and teachers are subject to change

Compulsory for these programmes: MSc in Taxation (Part Time)

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Tax Research Round Table

Core Course


The Tax Research Round Table core course will expose students to emerging ideas in the taxation field. Lecturers will be drawn from Oxford University, including non-tax faculty who will cast light on recent developments in other areas of law, for example public law, restitution and legal theory, or who will discuss research in economics, accounting or finance where these developments are significant for tax experts. In addition we may call on International Research Fellows of the Centre for Business Taxation or other external experts to give a paper regarding their research.

This course involves lectures during the residential week in Michaelmas Term Week minus one of Year 2, plus a session on essay writing. 

The extended essay topics will be based on the research papers chosen for the roundtable.

The course is led by Professor Michael Devereux and Professor John Vella. There will be other lecturers and guests participating.

Compulsory for these programmes: MSc in Taxation (Part Time)

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Tax Treaties

Elective


The Tax Treaties course focuses on the operation of double taxation conventions (more colloquially referred to as “tax treaties” and often abbreviated as “DTCs”). The emphasis is on the interpretation and application of DTCs, though students will also learn something about the negotiation of DTCs.

The course includes the following topics:

  • Introduction to the structure and operation of the principal model DTCs – the OECD Model Tax Convention (“MTC”) and the UN MTC
  • General provisions and definitions – especially the definitions of “resident” and “permanent establishment”
  • Business profits – Arts. 7 and 9 OECD MTC
  • Passive income – Arts. 10, 11, and 12 OECD MTC
  • Individuals – Arts. 15, 16, 17 and 18 OECD MTC
  • Methods of relief from double taxation – Art. 23 OECD MTC
  • Non-discrimination – Art. 24 OECD MTC
  • Settlement of international fiscal disputes – mutual agreement procedure – Art. 25 OECD MTC
  • The future role of DTCs

First year students are strongly encouraged to attend Tax Treaties, as it is a foundation for many of the other electives.

The course is taught by Visiting Professor Philip Baker QC.

Optional for these programmes: MSc in Taxation (Part Time)

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Taxation of Global Wealth

The Taxation of Global Wealth course examines UK tax and succession issues from the perspective of wealthy families and individuals who are either resident in the UK (even if temporarily) or hold assets situated here. Such wealth is typically held through trusts, foundations and similar vehicles; capital is far more international, diverse in nature and mobile than in the early 20th Century. Gone are the landed estates situated in one country on which estate duty was easily imposed. Taxing global wealth effectively and fairly presents particular challenges for governments, demonstrated by the fact that there is very little consistency in approach even within Europe. Common reporting and greater tax transparency of offshore vehicles has heightened the public debate on how they should be taxed. Conflict of law issues are also examined in the light of recent case law and some relevant equitable remedies including rescission and rectification.

Some knowledge of trusts or similar vehicles is helpful but not essential for the course.

The course is taught by Emma Chamberlain, Barrister, Pump Court Tax Chambers and Visiting Professor, Oxford Faculty of Law and Simon Douglas, Associate Professor of Law, Oxford Faculty of Law.

Optional for these programmes: MSc in Taxation (Part Time)

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Transfer Pricing

Elective


Problems in transfer pricing and profit attribution.

The Transfer Pricing course is concerned with the arm’s length principle and its application in the form of transfer pricing and profit attribution rules. The course provides an overview of transfer pricing and profit attribution from both a theoretical and practical perspective using case studies to illustrate the key principles, with a focus on the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations and the OECD’s guidance on PE attribution including the 2010 Report on the Attribution of Profits to Permanent Establishments. The course will consider the current debate on transfer pricing and profit attribution with a number of topical examples and the major conceptual, technical and practical problems of the income allocation rules will also be an especial area of focus.

The course includes the following topics:

  • Fundamental Sources
  • The Arm’s Length Principle and Comparability
  • Functional Analysis
  • Transfer Pricing Methods
  • Comparability analyses in practice
  • Intra-group services
  • Risk and capital
  • Issues raised by minimal function entities
  • Financing
  • Intangible property
  • Business restructurings
  • Permanent Establishments
  • Compliance issues
  • Avoiding Double Taxation/Dispute Resolution
  • The future of the income allocation rules/arm’s length principle

The course is taught by Dr Richard Collier, Associate Fellow at Saïd Business School and Professor John Vella

Optional for these programmes: MSc in Taxation (Part Time)

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US International Tax

Elective


The US International Tax course covers the principal features of United States federal income taxation of cross-border activities, including both inbound and outbound transactions, and both corporate and individual taxpayers. The aim is to provide students with a working knowledge of US tax concepts and terminology relevant to international transactions, as well as the main tax issues that arise under US law in respect of cross-border trade and investment. US income tax treaties and administrative practices are also covered, along with an overview of current US international tax policy initiatives in Congress and the Treasury Department.

The course will be taught by Professor Tsilly Dagan, Stephen E Shay, Senior Lecurer on Law, Harvard Law School and Professor Susan Morse, The University of Texas.

Optional for these programmes: MSc in Taxation (Part Time)