Master thesis

• Master thesis 2027/2028 full-time program - general topic: Withholding Taxation
  Withholding taxation is a central instrument through which states secure source-based taxation of cross-border income, and it lies at the intersection of domestic tax law, tax treaty law, EU tax law and international anti-abuse standards. Taking as its starting point the treatment of outbound and inbound payments under domestic law and bilateral tax treaties, the lecture aims to provide the conceptual and doctrinal foundations for understanding withholding taxes in an international and European context. It discusses the allocation of taxing rights over dividends, interest, royalties and other cross-border payments, the operation of treaty limitations on source-state taxation, and the practical significance of relief at source and refund procedures. Particular attention is given to the impact of EU law, including the fundamental freedoms, the Parent-Subsidiary and Interest-Royalties Directives, and the Court of Justice’s case law on discrimination, restriction and abuse. The lecture also addresses the role of beneficial ownership, anti-abuse doctrines, treaty shopping, and recent developments concerning administrative cooperation, transparency and enforcement. On the one hand, the lecture is intended to provide an introductory framework for more specialised lectures on international and EU tax law; on the other hand, it seeks to develop an understanding of how withholding taxation connects substantive taxing rights, procedural mechanisms and anti-abuse principles within the broader architecture of cross-border taxation.
• Master thesis 2027/2029 part-time program - general topic: Taxation of High Net Worth Individuals
• Master thesis 2028/2029 full-time program - general topic: Dispute Prevention and Resolution
  This course examines the entire field of tax dispute prevention and resolution from an holistic fashion. The aim is to introduce students to some of the key practical and legal issues in avoiding and, if necessary, resolving disagreements between taxpayers and the tax administration, including cross-border issues. The course will draw upon existing practice in a number of countries, plus proposals for reform. The aim is to cover the following sub-topics: 1. Dispute prevention by clear legislation and guidance, following taxpayer consultation 2. Dispute prevention by clearances – APAs and rulings 3. Dispute resolution by internal dispute procedures 4. Alternative dispute resolution 5. Domestic litigation – tribunals; courts; domestic appeals 6. Pan-national courts – CJEU; JCPC; other regional courts 7. Cross-border dispute resolution – MAP and other proposals (Pillar 1 and Pillar 2) 8. Cross-border dispute resolution – tax treaty-based arbitration 9. Investor-State arbitration and State-state arbitration 10. Other dispute resolution forms – e.g. ECHR and other regional HRs courts 11. Proposals for reform of dispute prevention and resolution
• Master thesis workshops
  These workshops are directly linked to the introductory class on the general topic and will be held while students are working on their Master’s theses. The participants are introduced to the techniques employed in writing an academic piece of work. Support will also be given on methods of research, using international literature, and its systematic review. Students have the opportunity to show the results of their work in the form of presentations, and to initiate discussion and debate on the topics concerned. The problems which are presented in the final thesis will be discussed in class and possible solutions sought.