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WU Vienna Tax law

Schedule

The University Act provides for a total of 90 ECTS for the LL.M. program. The program is divided into eight blocks of lectures and comprises the following subjects:
 

Principles of selected tax systems

  • This lecture aims to develop an understanding of tax systems in Africa and the context within which these systems originated and are still evolving. This necessitates a brief review of legal systems encountered in Africa as well as the different tax families. The relative importance of different taxes, such as corporate income tax, value-added tax and property taxes, will also be discussed. In a continent richly-endowed with natural resources, the appropriate taxation of petroleum and mining, in particular, is becoming increasingly important. Regional integration and tax harmonization will also be reviewed. Recent tax policy and tax administration reforms (such as the establishment of autonomous revenue authorities) in selected African countries will be discussed.
  • This course provides a broad overview of the Australian taxation system and compares various aspects of it with aspects of the tax systems in Malaysia, Singapore, and New Zealand. The course discusses the key similarities and differences that exist between the regimes in the respective jurisdictions from both a legal and policy perspective. It focuses on residency rules, goods and services tax, income tax, corporate and shareholder taxation, international taxation and investment and savings incentives.
  • This course provides an overview of Australian taxation law and tax law concepts. It serves as an introduction to common law tax concepts such as the role of discretionary trusts and the capital/revenue distinction common to almost all Anglo jurisdictions and contrasts those concepts with civil law understandings. It focuses on Australia's three most important Commonwealth taxes: goods and services tax (the Australian VAT), income tax, and fringe benefits tax and examines all three in in the context of similarities and differences between common law and civil law tax concepts and principles. It considers, for example, the Australian company and shareholder imputation system in contrast to the former European imputation systems and current classical system and contrasts the Australian and other modern VAT systems with the traditional European VAT. It similarly compares the regime used in Australia (and several other countries) to tax employee fringe benefits with the system used in Europe and North America and the system used to tax retirement savings with the European and North American system. Key aspects of Australia's international tax rules are also examined in the course and the tax treaty issue that arise in relation to potential double taxation of retirement savings, fringe benefits, and other types of income subject to different tax rules in Australia and its treaty partners.
  • Although with its origins in the pioneer North American experience and its classical prototype of federation, Brazilian federalism deviates from the original model and presents its own peculiarities. In an attempt to avoid internal double taxation, the Brazilian Constitution not only granted tax jurisdiction to all levels of government but also allocated the taxes themselves among the three federal subdivisions. This characteristic of the Brazilian tax system has led to relevant outcomes, such as tax jurisdiction conflicts, harmful tax competition among the States (a so-called “tax war”) and an undesirable multiplicity of taxes on consumption which are distributed among the three federal subdivisions and which do not generate reciprocal credits and may be levied in the same production chain. The course is aimed at providing an overview of the Brazilian tax system and its mechanisms, the complexity of which is a challenge to the delicate Brazilian federal arrangement.
  • As one of the most dynamic economy in the world, China attracts a large number of foreign investors to do business in China each year. Meanwhile, China’s capital and/or technology exports are also growing year by year. The increase of cross-border investments and transactions among China and other parts of world has highlighted the importance of comprehensive understanding of China’s economic policies, especially its domestic and international tax policies, with which tax practitioners may help investors make reasonable arrangements for their Chinese business. It turns out that China’s tax policies are quite different from those of other countries. More importantly, the digitalization of economy has disrupted what tax practitioners was familiar with and provoked the variation of domestic tax policies in each country, including China, and the reshape of the international tax order as well. In shaping new rules for international taxation, China has made its contribution and will likely play a role in the future. This course introduces students to the basic components of China’s tax system, especially income tax and value added tax system, and discusses China’s practice and potential role in reshaping the international tax order.
  • own distinct features resulting from different tax policy choices and often deep cultural differences. Aside from its practical value to tax practitioners dealing with transnational transactions, comparative tax law has become a significant discipline in the literature of tax law and policy because it is an important means by which tax students and practitioners can enrich their understanding of their own tax systems and can learn about the factors that determine tax legislative outcomes in different countries. In this course a number of the leading studies in comparative tax law will be examined in order to discern the deep structure of the income tax, how tax laws reflect the values and institutions of different countries, and the extent to which one country can transplant tax laws from another country in order to improve its tax system.
  • The course aims to provide the necessary understanding for a systematic approach to the field of German tax law in general. It discusses basic issues such as the scope of income tax law and corporate tax law, the assessment of taxable income, deductions and refunds, special approaches in taxing labor income as well as capital income and the most important rules and instruments of general tax law. In addition, the most important anti-abuse measures are presented, e.g. CFC rules, extended limited tax liability. On the one hand, the course intends to create a basis for various, more specific courses, and, on the other, to develop an understanding of the interrelations between tax law and constitutional law as well as European law.
  • India is developing fast as a major international center for cross-border trade and investment. As a country that favors source-based taxation, it largely follows the United Nations Model in its treaties. Moreover, its domestic tax law and practice often promote its national economic and social policies and are not determined by just fiscal considerations. This course will provide a broad understanding of the current Indian tax system. In particular, the course will cover the international tax framework (both law and practice) under domestic law and the role and interpretation of tax treaties based on various administrative and judicial decisions in India and rulings given by its Authority for Advance Rulings.
  • The lecture aims to provide the necessary understanding of the South African tax law system - its origins and bases. It will briefly touch on “other taxes”, such as VAT, where relevant. It will deal with existing cross-border issues and developments such as cross-border services, deemed source and CFC rules, among other things. It will highlight the importance of mutual agreement procedures and the exchange of information. The treaty network that currently exists will also be covered. Specific and general anti-avoidance provisions and rules will be highlighted.
  • The course on Swiss tax law is divided into three parts and begins with an overview of the Swiss federal tax system and the most important constitutional and legislative principles governing Swiss tax law. The second part of the course deals with the most important types of taxes, particularly with the individual and corporate income taxes levied on the federal and the cantonal level. The third part, finally, focuses on international tax law topics, in particular the Swiss tax treaty policy, the multilateral agreements on tax issues signed by Switzerland and the tax relevant aspects of the relationship between Switzerland and the EU.
  • This course deals with the national and international tax system of the Netherlands by examining general characteristics, the taxation of profits, capital income and capital gains, fiscal consolidation, mergers and de-mergers, participation exemption, abuse of the law, partnerships, rulings practice, and tax treaty policy.
  • The Nordic countries have much in common as far as legal culture and legal structure are concerned, even though only three of the five countries are members of the EU. However, there are also significant differences, not least within the field of tax law. This course provides a general overview of the Nordic tax systems by focusing on issues of special interest to students from non-Nordic countries. Attention is given to three main areas: first, issues of general theoretical interest, such as dual income tax; second, essential rules of particular importance for foreign investors and Nordic domestic companies investing abroad; and third, international tax issues which deal with the Nordic multilateral tax treaty, together with the main principles of international tax law in selected Nordic states.
  • The aim of this course is to analyze how European integration influences the structure of tax systems in the different Member States, from a legal and a policy prospective. It is divided in four parts. First, it provides for a general comparison on the similarities and differences of EU Member States’ tax systems as regards the types and relative importance of taxes. Then it identifies the different EU instruments susceptible to impact directly or indirectly Member States tax laws and policies, such as regulations and directives, ECJ case-law and soft law, both in tax and non-tax areas, such as environmental policy and budgetary control. Thirdly, it analyses specific examples of this EU influence in the area of corporate and income tax, such as anti-avoidance rules, tax incentives or taxation of cross-border situations. The fourth and last part is devoted to taxpayers rights, showing the essential role of European law in enhancing the domestic protection of taxpayers across Member States.
  • This course offers an introduction to federal income taxation in the United States. The first day will focus on domestic taxation, including the tax treatment of households, corporations, and other business entities (partnerships and LLCs). Students will learn the sources of U.S. tax law and gain familiarity with recent legislative proposals. The second day will focus on international taxation and will introduce students to the tax treatment of inbound and outbound transactions. This discussion will include source and residency rules, the new GILTI regime for multinational corporations, the foreign tax credit, and foreign-account reporting requirements.

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