Last modified: 16 Sep 2025 12:46
The course will examine the law and principles of cross-border taxation. It will cover core subjects on international tax law, including the concepts of source and residence taxation, double tax conventions, allocation of taxing rights, transfer pricing and thin capitalisation rules, and international tax avoidance (schemes and prevention).
Attention will be paid to topical issues around international taxation and the efforts being made to modernise the international tax system. This includes an examination of the tax challenges of the digital economy and the solutions introduced by the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting. The progress and challenges associated with the recent resolution to establish a new UN Framework Convention on International Tax Cooperation will also be examined.
The course content fulfils the core requirements of Module 1 of the ADIT (Advanced Diploma in International Tax) qualification offered by the Chartered Institute of Taxation. The course is also essential for those aiming to practise tax in an international context, either as academics, government officials, or general tax advisors.
The course will be taught from a legal and policy perspective. No prior knowledge of tax is required, but students should be willing to engage with the tax literature and tax affairs.
| Study Type | Postgraduate | Level | 5 |
|---|---|---|---|
| Term | First Term | Credit Points | 30 credits (15 ECTS credits) |
| Campus | Aberdeen | Sustained Study | No |
| Co-ordinators |
|
||
This course aims to guide students through the principles and rules of taxation in the context of cross-border trade and investments. Upon completing the course, students should be able to understand the legal framework of international tax law, apply the analytical tools to real-life problems, such as international tax planning and anti-avoidance practice, and appreciate important policy issues.
The course content is divided into four parts.
Part one introduces students to basic principles of international tax law, including jurisdiction to tax, the concepts of residence and source taxation, double taxation, and methods of relief from double taxation.
Part two discusses the OECD and the UN model tax conventions, covering topics such as permanent establishment, the allocation of taxing rights on business profits and investment incomes, and the taxation of the digital economy.
Part three examines transfer pricing and thin capitalisation rules, including the OECD, UN and domestic law approaches to transfer pricing.
Part four considers various international tax avoidance schemes, domestic approaches to international tax avoidance, the OECD Base Erosion and Profit Shifting project and the proposed new UN Framework Convention on International Tax Cooperation.
Information on contact teaching time is available from the course guide.
| Assessment Type | Summative | Weighting | 50 | |
|---|---|---|---|---|
| Assessment Weeks | 39 | Feedback Weeks | ||
| Feedback |
The feedback will be provided in written form and in accordance with the Common Grading Scale. The feedback will be provided within three weeks as of submission, in accordance with the School’s and University’s policies |
|||
| Knowledge Level | Thinking Skill | Outcome |
|---|---|---|
| Conceptual | Analyse | To assess the efficacy of specific international tax rules by referring to the basic principles and analytical tools acquired in the course. |
| Conceptual | Understand | To gain understanding of the legal framework and basic principles of international taxation. |
| Procedural | Apply | To apply the principles, rules, and intellectual tools to international business scenarios, such as dual residence, transfer pricing, and international tax planning. |
| Reflection | Create | To communicate orally and in writing information, advice and choices in an effective and persuasive manner. |
| Reflection | Evaluate | To engage with the discussion of the cutting-edge issues in the domain of international taxation. |
| Assessment Type | Summative | Weighting | 50 | |
|---|---|---|---|---|
| Assessment Weeks | 30 | Feedback Weeks | 33 | |
| Feedback |
The feedback will be provided in written form and in accordance with the Common Grading Scale. The feedback will be provided within three weeks as of submission, in accordance with the School’s and University’s policies. |
Word Count | 3000 | |
| Knowledge Level | Thinking Skill | Outcome |
|---|---|---|
| Conceptual | Analyse | To assess the efficacy of specific international tax rules by referring to the basic principles and analytical tools acquired in the course. |
| Conceptual | Understand | To gain understanding of the legal framework and basic principles of international taxation. |
| Reflection | Create | To communicate orally and in writing information, advice and choices in an effective and persuasive manner. |
There are no assessments for this course.
| Assessment Type | Summative | Weighting | 100 | |
|---|---|---|---|---|
| Assessment Weeks | Feedback Weeks | |||
| Feedback |
Re-submission of failed element in re-sit diet; the failed course will be capped at grade 09 (D3). |
|||
| Knowledge Level | Thinking Skill | Outcome |
|---|---|---|
|
|
||
| Knowledge Level | Thinking Skill | Outcome |
|---|---|---|
| Conceptual | Analyse | To assess the efficacy of specific international tax rules by referring to the basic principles and analytical tools acquired in the course. |
| Conceptual | Understand | To gain understanding of the legal framework and basic principles of international taxation. |
| Procedural | Apply | To apply the principles, rules, and intellectual tools to international business scenarios, such as dual residence, transfer pricing, and international tax planning. |
| Reflection | Create | To communicate orally and in writing information, advice and choices in an effective and persuasive manner. |
| Reflection | Evaluate | To engage with the discussion of the cutting-edge issues in the domain of international taxation. |
We have detected that you are have compatibility mode enabled or are using an old version of Internet Explorer. You either need to switch off compatibility mode for this site or upgrade your browser.
