International Tax

|

LLM

|

Part Time, Full Time

| Admissions status: Open
This Tax LLM will equip you with the legal framework and intellectual tools you need to understand cross-border tax. With a reputation for exceptional teaching and contemporary expertise you will find your intellectual and creative abilities are both challenged and developed by this demanding but intensely practical subject. You may also prepare simultaneously for the CIOT Advanced Diploma in International Taxation.

KEY BENEFITS
  • Opportunity to prepare simultaneously for the Chartered Institute of Taxation (CIOT) Advanced Diploma in International Taxation.
  • Exceptional teaching reputation; unique, sought-after expertise, contemporary experience and connections with the wider London legal community.
  • Unrivalled location in the heart of legal London; based in the magnificent East Wing of Somerset House on the Strand and minutes from the Royal Courts of Justice, the Inns of Court and offices of major City law firms.
  • For more in-depth information listen to the LLM in International Tax podcast.
KEY FACTS
Student destinations
LLM graduates go into or continue with a variety of careers including: legal profession; banking and finance; accountancy; management consultancy; human rights organisations and other voluntary bodies; academia.
Programme leader/s
Professor Jonathan Schwarz
Accreditation
Law Society CPD points
Awarding Institution
King's College London
Credit value (UK/ECTS equivalent)
UK 180/ECTS 90
Duration
One year FT, two to four years PT, September to September.
Location
Strand Campus.
Year of entry 2013
Offered by
The Dickson Poon School of Law
Closing date
31 March 2013 (FT and PT). Only complete applications will be considered after this date.
Intake
Overall LLM intake 360 (FT and PT).
Fees
PT Home: £6300 (2013)
PT Overseas: £9200 (2013)
FT Home: £12600 (2013)
FT Overseas: £18400 (2013)
CONTACTS
Contact information
Postgraduate Officer, Centre for Arts & Sciences Admissions (CASA)
tel: +44 (0) 20 7848 2097 / 2711
fax: +44 (0) 20 7848 7200
Email

PURPOSE
The programme allows you to deepen and broaden your knowledge of law in this area and will assist your professional development in these fields. While intellectually rigorous it also keeps you grounded in real life practice by drawing on the real world experiences of our teaching faculty. Aimed at recent law graduates (or graduates of joint degrees with a significant legal content) as well as established legal or other professionals who may have graduated a number of years ago, the programme is rigorous and demanding.

DESCRIPTION

On this LLM you will learn how tax works, how adding or subtracting a single step can change corporate transactions, or government policies, and determine whether they succeed or fail.

The King's specialist LLM in International Tax is lead by Professor Jonathan Schwarz, practicing barrister, who is well recognised for his tax expertise. King's tax modules are open to those with or without previous tax experience but we expect all out students to be able to analyse legal and commercial concepts and then apply them to a complex factual matrix. You will need creativity, intellectual rigour and a willingness to work hard. We think the rewards are worth it.

Many of our students go on to enjoy successful employment with some of the world's leading firms and institutions. Some have made the decision to specialise in tax but not all. A tax module can be an enhancement to other studies, such as in commercial, financial or EU law for example.

Whatever your reasons for exploring International Tax, our LLM programme provides an excellent springboard for a wide range of careers, including traineeships with global partnerships, legal firms or placements with EU institutions.



STRUCTURE OVERVIEW
Core programme content

You need to study full- or half-modules worth 180 credits.

Each module is worth 40 credits (with half modules worth 20 credits). You will need to select modules of your choice that adds up to 120 credits in total.

To achieve the additional 60 credits you need to choose between:

  • Writing a 15,000 word dissertation
  • Writing a 7,500 word research essay related to a taught module and then study another half-module of your choice


The modules listed below are those related specifically to the LLM in International Tax. The general Master of Laws entry lists all available LLM modules.

NB! Students considering completing the LLM in International Tax on a part-time basis and thus planning to continue their studies into 2013-14 should note that at this stage of the cycle it cannot yet be confirmed which of the modules below will be offered in 2013-14. These details are expected to be confirmed at the beginning of the 2012-13 academic year, and part-time students will be advised to take this into account before making their final selection of modules for 2012-13.



FORMAT AND ASSESSMENT

In the first and second semester you study your selection of taught modules (half and full). These are in most cases assessed in the third semester (May/June) by written examination, or in some cases the submission of an assessed essay.



MODULES
More information on typical programme modules.
NB it cannot be guaranteed that all modules are offered in any particular academic year.


Teaching staff: Professor Jonathan Schwarz and Kelly Stricklin-Coutinho
Module code: 7FFLA069
Credit level: 7
Credit value: 40
Semester:  Full-year 
Assessment:  written examination/s 
Three-hour exam.

Module description

This module examines the impact of EU law on taxation in the Member States. It examines the sources of EU law and its conceptual framework; considers harmonisation measures that have impact on taxation, including the direct tax directives designed to eliminate cross-border distortions and the application of the State Aid rules to taxation; and concludes by examining the impact of the Treaty freedoms of movement on the Member States' direct taxation rules as revealed through the Courts' case law.
Teaching staff: Professor Jonathan Schwarz and Tom Wesel
Module code: 7FFLA035
Credit level: 7
Credit value: 40
Semester:  Full-year 
Teaching pattern: 

Weekly two-hour exam.

Indicative/suggested reading: Schwarz on Tax Treaties, 2nd Edition (CCH) by Jonathan Schwarz; Principles of International Taxation 3rd Edition (Bloomsbury Professional) by Angharad Miller and Lynne Oates.


Assessment:  written examination/s 
Three-hour exam.

Module description

This module considers taxation in an international context. Domestic tax systems have increasingly had to respond to globalisation so that taxation can still be viable in an environment where activities which have traditionally attracted taxation can be carried out without domestic borders to define their scope. The module will consider taxation and international law in general and then move on to looking at the ways in which domestic systems have sought to deal with double taxation where activities attracting taxation are carried out over more than one country – namely through double taxation conventions. The focus will be on the OECD Model and double taxation conventions based on this and why international business gives tax systems a problem and how this can be addressed.
Teaching staff: 

Mr Tom Wesel


Module code: 7FFLA055
Credit level: 7
Credit value: 40

The taxation of an estate is a complex yet fundamental issue for many taxpayers. Tax can be levied both during the lifetime of the taxpayer and on his or her death. This module considers how an estate might be taxed, both during life and on death and looks further to see how legitimate tax planning can be used to reduce taxation. The module considers a number of taxes, but the focus is on income tax, capital gains tax and inheritance tax.

It begins with a detailed analysis of the rules in relation to each of these taxes. As many tax planning methods utilise trusts, the module pays particular attention to the treatment of each of these taxes towards trusts. As the module progresses, the understanding of these rules is put into practice by considering specific circumstances where tax planning can be used , including an understanding of how tax planning works on the International level.
Teaching staff: 

Anne Fairpo and Tom Wesel


Module code: 7FFLA056
Credit level: 7
Credit value: 40
Semester:  Full-year 

Taxation is a key factor in business decisions, and how to raise tax from businesses without damaging the economy is a central element in all government’s policy.

In this module we will examine the taxation of businesses under UK income tax, corporation tax and capital gains tax. We will also consider, to a lesser extent, VAT, the UK interaction with foreign taxes, and stamp duty.

Although it is based around the UK tax system, the module deals with questions about the taxation of businesses that face all tax systems. Its object is to provide a solid grounding in the principles of the taxation of businesses, and the main rules will be studied in depth in the context of those principles.
Teaching staff: Professor Jonathan Schwarz
Module code: tbc
Credit level: 7
Credit value: 20
Semester:  Semester 1 (autumn) 
Teaching pattern: 

Weekly two-hour seminars.

Indicative/suggested reading: OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, July 2010.


Assessment:  written examination/s 
Two-hour exam.

Module description

Transfer pricing is the single biggest issue in international taxation for multinational business and tax administrations. The aim of this module is to critically and comprehensively analyse the legal issues pertaining to Transfer Pricing and is addressed to lawyers, accountants and tax policy-makers, whether in private practice, as in-house counsel, or government employees. The course takes a practical, transactional and multi-jurisdictional perspective and examines in depth the OECD Transfer Pricing Guidelines including the rules and Commentary of the OECD Model Tax Convention together with a detailed analysis of transfer pricing disputes and practice including the expanding body of case law.

Teaching staff: 

Robert Hartley


Module code: 7FFLA537
Credit level: 7
Credit value: 20

Value Added Tax is an increasingly important tax in the UK and throughout the EU. Not only does it generate a large amount of revenue for governments, its character as a European tax makes for interesting case law and controversy within domestic systems.

This module considers the nature of VAT as a tax and considers the system of VAT as implemented in the UK. It considers the various elements of the tax and how the tax has developed in response to EU movement and pressure.

As well as gaining a comprehensive understanding of VAT in the UK, the aim of the module is to provide you with the tools to be able to comprehend other systems of VAT in Europe and also to understand why what seems like a simple tax has proved so complicated in the EU.

ACADEMIC ENTRY REQUIREMENTS
General entry advice

Applicants who wish to enrol for the LLM in International Tax may apply for admission on the basis of one of the following two paragraphs:

1. The applicant must hold a recognised first degree in law (or a degree with at least 70% law content) of at least high upper second class honours standard or an equivalent overseas qualification

OR

2. The applicant must:
(i) hold a recognised first degree in any discipline of at least high upper second class honours standard or an equivalent overseas qualification (with a preference for degrees in accounting or other tax-related fields); AND
(ii) have at least 12 months’ appropriate work experience in the Tax sector.

Applicants fulfilling both the requirements contained in paragraph (2) may therefore apply to the LLM in International Tax even though they do not hold a first degree in law (or a degree with at least 70% law content) as would otherwise be required under paragraph (1) above. This entry route is intended for applicants who do not have a law degree but who have appropriate work experience in Tax, and who may previously have considered enrolling for our MA Tax programme (the MA Tax programme has been discontinued with effect from 2013-14).

Please note that applicants admitted to the LLM in International Tax on the basis of paragraph (2) above must enrol for this specialist LLM programme only. Following admission, they will not be permitted to enrol for any other specialist LLM (such as the LLM in International Financial Law or the LLM in Competition Law) or for our general LLM programme, and will be obliged to select only modules offered under the LLM in International Tax.

Part-time applicants: please note that The Dickson Poon School of Law requires that part-time students applying to a postgraduate law programme must work for a minimum of 22 hours per week. You will be asked to supply an official letter from your employer stating that you work for at least 22 hours or more per week.


APPLYING TO KING'S
To apply for graduate study at King's you will need to complete our graduate online application form. Applying online makes applying easier and quicker for you, and means we can receive your application faster and more securely.
King's does not normally accept paper copies of the graduate application form as applications must be made online. However, if you are unable to access the online graduate application form, please contact the relevant admissions/School Office at King's for advice.

APPLICATION PROCEDURE

Applications must be made online using King's online application portal. Applications may be submitted from 1 October 2012.

At the start of the semester you will have the opportunity to attend taster lectures and to speak to module leaders before you make a decision on whether to do a specialist or tailored LLM.

Please see the LLM FAQ's pdf document for further information on the LLM application process.



PERSONAL STATEMENT & SUPPORTING INFORMATION

Please see the LLM FAQ's pdf document for further information on how to complete your application.



FUNDING
Home: AHRC, self-funded, career development loans. EU: AHRC. Overseas: British Council, Association of Commonwealth Universities. The Dickson Poon School of Law offers two LLM Entrance Scholarships per year: one covering full home/EU fees; one covering full overseas fees.


Student profiles

International Tax LLM

I graduated with a double degree (French and English Law) from the University of Exeter. I studied in France for one year and was then introduced to Tax Law. Taxation is usually not studied at an undergraduate level but it is none the less a very complex and wide area of the Law; a Tax LLM is definitely an asset for those who want to specialise in this field.

The worldwide reputation of King's was indeed one of the reasons why I decided to apply to the College but it was also because it is one of the few to offer an LLM specialised in Tax Law.

The lecturers are very approachable and always helpful; they are top practitioners in their field. Small group sessions and voluntary assessments are often organised to make sure that everyone is up to date.

The Strand Campus is ideally located in the heart of London and easily accessible. Being a student at King's gives us access to amazing facilities such as the Institute of Advanced Legal Studies.

Finding a place to live in London is not as hard or expensive as one should think. House share is very common and the College offers a wide range of accommodation situated all over the city for those who do not wish to live in private accommodation.

Every Thursday, all LLM students have the possibility to meet for a drink which is always a good way to encounter other students with the same interest but with a different cultural background.
International Tax LLM

The course involves a lot of self-preparation, and I was very impressed by how much additional help the teachers were giving. The library is particularly good, stocking the latest items on tax planning and subscribing to a broad variety of useful online resources. I also found the Careers Service's work very comprehensive, always organising employment events and running workshops.

The university follows a very practical approach in its teaching techniques, as well as offering all-round student support, which, I believe, will give me a substantial advantage in the competitive job market.