International Tax
|LLM
|Part Time, Full Time
| Admissions status: OpenYou 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.
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.
NB it cannot be guaranteed that all modules are offered in any particular academic year.
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.
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.
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.
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.
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.
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.
