Study:	Tax - 3. semester
Code:	111445
ECTS:	4.0
Course coordinators:	prof. dr. sc. Hrvoje Arbutina
Lecturers:	dr. sc. Irena Klemenčić - Lectures
Exam dates:	10. 06. 2024. 24. 06. 2024. 08. 07. 2024. 26. 08. 2024. 09. 09. 2024. Exam registration: Studomat

Literature:

Lončarić Horvat, Olivera, i Hrvoje Arbutina; Osnove međunarodnog poreznog prava; Narodne novine (2007), str

Description:

Significance and basic problems of the international tax law. Basics of the international tax law Principles of the international tax law. Scope of the tax obligation (personal, objective scope - unlimited and limited tax obligation). International double taxation. Definition. Significance. Kinds of international double taxation. Means of avoidance of international double taxation. Models of the conventions for the avoidance of the international double taxation. Legal status of the double taxation conventions. Interpretation of the double taxation conventions. Methods of the avoidance of the international double taxation. Structure of the double taxation conventions by the articles . Internationally organized tax evasion and avoidance. Kinds of internationally organized tax evasion and avoidance. Off-shore centres. Transfer pricing. Treaty shopping. Thin capitalisation. Countermeasures. International co-operation of tax administrations. Other issues of international tax law. E-commerce. Attribution of profits to the permanent establishment. Triangular cases. Tax treatment of partnerships. Tax treatment of financial instruments. Harmful tax competition.

Cognitive Skills:

Knowledge and understanding

After successfully completing the course, students will be able to:

- define basic categories of international tax law in the context of modern legal approaches;

- critically evaluate and recognise basic factors of the occurrence of international tax law relations;

- explain theoretical approaches and define differentiation criteria in solving individual international tax law problems;

- explain the differences in the aforementioned approaches;

- indicate modern theories about determination of the scope of tax obligation;

- explain research methods that are the basis for original thinking and scientific research in international tax law.

 

Application

After successfully completing the course, students will be able to:

- group and describe categories of international tax law;

- understand the difference in tax law approach in tax systems of different countries

- apply the knowledge about these different systems in the analysis of resolution of different tax-law problems in these systems;

- outline application of research methods.

 

Analysis

After successfully completing the course, students will be able to:

- categorise causes of the creation of individual solutions of international tax law, relations within it and material effects that it produces;

- demonstrate causes of the occurrence of individual problems within international tax law;

- analyse criteria for differentiating between national and international tax law;

- compare the role of national tax-law system and comparative tax systems in different periods;

- analyse various theories about international tax law.

 

 

Synthesis

After successfully completing the course, students will be able to:

- construct the connection between solutions in international tax law with basic elements of tax law in general;

- propose a change of individual research methods for certain international tax law phenomena;

- formulate causes of the occurrence of certain international tax law phenomena;

- distribute the roles of various factors in the creation of certain international tax law phenomena;

- form a plan for the application of a research method in the analysis of one or more international tax law phenomena in a relevant modern country.

 

 

 

Practical and Generic Skills:

After successfullly mastering the course, students will be able to:

- publicly present learning outcomes;

- express themselves in a clear and structured manner while explaining their standpoints;

- develop communication skills;

- participate in team work.

Matching Assessments to Learning Outcomes:

- testing knowledge should enable testing of acquired learning outcomes within the course

- it is important taht learning outcomes form a basis of knowledge that will be tested and the manner in which these outcomes will be tested

- every outcome should be tested

Consultations schedule:

• prof. dr. sc. Hrvoje Arbutina:

  Wednesday 13 - 14:30 (ĆM 4, office 8, ground floor)

  Location: Ćirilometodska 4, room 8
• dr. sc. Irena Klemenčić:

  Appointment by e-mail

  Location: Ćirilometodska 4, room 45