The aim of the module is to give students an understanding of the principles underpinning, and the risks inherent in, double taxation relief and other international tax issues including EU tax harmonisation, the implications of the single market, the impact of offshore business, transfer pricing and trends in world tax systems.

Explanation of the Irish domestic legislative provisions which govern the territorial rules for assessing individuals and companies to income tax /corporate tax and capital gains tax; Concept of double taxation and foreign tax credit relief including both bilateral and unilateral reliefs; Interpreting the OECD Model Double Taxation Convention and explaining how companies can interpret domestic laws in different jurisdictions and relevant conventions to create tax planning opportunities; Explaining the concept of Transfer pricing and the rationale behind the CCCTB; Explaining the different territorial rules in other countries explaining residence , source and territorial concepts ; Considering other countries anti deferral tax rules including Controlled Foreign Company legislation; Evaluation of the types of business models used by multinational companies to reduce their global effective rate of tax; Explain the rationale for changes in both domestic and International Tax legislation and policy in relation to corporates and individuals.

Determine the Irish domestic legislative provisions which govern the territorial rules for assessing individuals and companies to income/corporate tax and capital gains tax * Critically evaluate the types of business models used by multinational companies such as Limited Risk Distributorships , Commissionaires. * Compute the Irish tax position for companies receiving dividends from overseas subsidiaries located in high tax and low tax jurisdictions * Interpret International Double Tax Treaties in the context of assessing different types of income, profits and capital gains to taxation in different countries. * Evaluate the application of capital gains tax exit charges for both individuals and companies ceasing to be tax resident in Ireland. * Identify distinguishing features of how different jurisdictions (including Ireland) treat holding companies set up in their jurisdiction. * Appraise the key tests applied in determining whether a particular activity undertaken by a company qualifies for the 12.5% Corporate tax rate. * Distinguish the key tax factors which an investor or developer will evaluate in considering an overseas property investment or development * Explain the rationale for changes in both domestic and International Tax legislation and policy

Understand the tax payers' Charter of Rights in ensuring tax payers' compliance with tax law; Appreciate the need to administer and apply tax law and practice in a fair and consistent basis;

N/A

Lecture format with a strong emphasis on practical application of the relevant legislation, case law and developments in practice.