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This course is mainly a policy course and deals with the structural problems of setting up an income tax system in general, without dealing with any specific tax system in detail. It deals with problems like the comparison between schedular and global income tax, the relationship between personal and corporate income tax, double taxation of corporate profits, the international implications of cross border flows of income, taxation of capital gains, family taxation and the integration of social security systems in income taxes (social benefits and pensions). Reference to existing tax systems is mainly used by way of example to illustrate structural and policy problems. |
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This course gives an introduction to VAT as it has been implemented through the E.U. directives and the case law by the European Court of Justice and further deals with the general structure of excises and other consumption taxes (sales taxes). The VAT part deals with policy and practice problems, the other part mainly with policy problems.
This is a basic general course of international taxation dealing with the causes of double international taxation, the interpretation of tax treaties and the commentary on the OECD model treaty. The course deals with policy issues as well as with problems of professional practice.
This course deals with the impact of European community law on the national tax systems of the Member States. It is policy and practice oriented. It deals with (1) the taxing powers of the E.U., (2) the impact of Treaty provisions on indirect and direct taxation and international treaty law through the case law of the European Court of Justice, (3) the major directives and draft directives in the area of income taxation (4) the major policy issues in the area of tax competition and tax harmonisation or coordination.
The course Capita Selecta will deal with specific topics of European and international taxation, and will be lectured by the professor holding the annually rotating PwC Chair.
This course contains an introduction into the tax system of the U.S. and of some major tax jurisdictions in Europe: United States (David Cameron, Northwestern University, Chicago ), United Kingdom (David Salter, Oxford), Germany (Joachim Englisch, Cologne University, Cologne), France (Emmanuel de Crouy-Chanel, Sorbonne, Paris), the Netherlands and the Netherlands Antilles (Peter Essers, Tilburg University, Tilburg), Belgium (Jacques Malherbe, UCLouvain, Brussels), Luxembourg (Jean-Pierre Winandy, Loyens Winandy, Luxembourg) and Switzerland (Robert Danon, Lausanne University, Lausanne). Each course consists of maximum 12 contact hours. Finally there will be a session of 12 hours on a comparative and international study of inheritance, gift and estate taxes.
The course consists of the following topics: (1) the basic structural rules for the taxation of various forms of mergers and acquisitions in France, Germany, The Netherlands, the United Kingdom and the USA; (2) an in-depth study of the rules of European law on various forms of mergers and acquisitions; (3) an inventory of specific problems of cross-border mergers and acquisitions; (4) case studies of different forms of mergers and acquisitions.
The course consists of in-depth study of: (1) the various methods of transfer pricing calculation and the application of the OECD guidelines; (2) the possibilities of advance transfer pricing rules; (3) the possibilities for negotiating with the tax administration on the requirements of documentation; (4) the procedural implications of a transfer pricing conflict; (5) the actual and potential use of the European arbitration convention in solving transfer pricing problems.
After a short introduction on what financial instruments actually are, the course will focus on the tax rules concerning financial instruments. All three sorts of financial instruments (equity or debt-based, risk management and employee benefit) are addressed. Among others, the following themes receive special attention: (1) the differences between equity and loans for cooperate and personal income tax and the financial instruments in the twilight zone in between (e.g. warrant loans); (2) the fiscal treatment of financial risk-management instruments such as options, swaps, forwards and futures; (3) the fiscal treatment of employer and employee if stock options are granted; (4) the treatment under VAT rules of financial instruments.
This exercise consists of the preparation of court briefs and the oral defence before a jury of a case on international and/or European tax problems. Every student is acting as one of the parties involved in the court procedure (plaintiff or defendant) or as Advocate-General to the European Court of Justice.
A master paper of approximately 30-35 pages, and of a quality that can be published in a tax review of high standing, on a subject chosen from and initiated in one of the special subject courses, or in the moot court.