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WU Vienna Tax law


Riël Franzsen

Riël Franzsen occupies the South African Research Chair in Tax Policy and Governance in the Faculty of Economic and Management Sciences at the University of Pretoria. He is also the director of the African Tax Institute at the University of Pretoria. He holds two undergraduate degrees and a doctorate in law with a thesis on South Africa’s real estate transfer tax. He also holds a master’s degree in creative writing. He has acted as policy advisor in Africa, Asia, Europe, and the Caribbean on behalf of various entities, including the International Monetary Fund (IMF) and World Bank, on especially property tax issues. He has been a co-instructor for property taxation courses offered on behalf of the IMF (Austria and Singapore) and on behalf of the Lincoln Institute of Land Policy (China and Slovenia). He is a member of the Board of Advisors of the International Property Tax Institute (IPTI) and has authored or co-authored numerous conference papers, journal articles, and book chapters on land and property taxes in particular. He is co-editor and co-author of Property Tax in Africa - Status, Challenges, and Prospects, published in 2017 by the Lincoln Institute of Land Policy.

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, customs duties, 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 will allow students to examine the main policy and technical issues involved in the negotiation of tax treaties. It will first explore the main elements that determine a country's tax treaty policies, including the relevant features of its domestic tax system and economic factors. It will then focus on the identification of the main issues involved during the negotiation of each article of a typical tax treaty. The course will also examine the various steps for the conclusion of a tax treaty and the process of negotiation, taking into account the role of model conventions and previously concluded treaties.

The course will be a broad-based discussion of US cross-border tax issues, from both an inbound and outbound perspective. Planning considerations will be emphasized. The first day will concentrate on investments by foreign persons into the United States, and will include taxation at source on portfolio income, net income taxation, use of hybrid and reverse hybrid vehicles, and related treaty issues. The second day will concentrate on foreign activities of US taxpayers and will include an overview of major transfer pricing issues from the US perspective.

The principle of ability to pay is significant for the doctrine on and structure of German tax law. Taking this as a starting point, 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.

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