Taxation of International Business is an elective subject in postgraduate programs offered by the Faculty of Law. This subject considers jurisdiction to tax and the Australian taxation of overseas business transactions, international financial transactions and investment, with special emphasis on the Asia-Pacific region.
|Academic unit:||Faculty of Law|
|Subject title:||Taxation of International Business|
Delivery & attendance
|Attendance and learning activities:||There will be 12 seminars in the 191 semester. Attendance and participation will be monitored and students who fail to attend at least 80%of seminars will be refused assessment. Seminars build on the work of the previous session. It is extremely difficult to recover if you miss a seminar. Seminars will not be streamed.|
|Prescribed resources:|| |
|[email protected] & Email:||[email protected] is the online learning environment at Bond University and is used to provide access to subject materials, lecture recordings and detailed subject information regarding the subject curriculum, assessment and timing. Both iLearn and the Student Email facility are used to provide important subject notifications. Additionally, official correspondence from the University will be forwarded to students’ Bond email account and must be monitored by the student.|
To access these services, log on to the Student Portal from the Bond University website as www.bond.edu.au
Assumed knowledge is the minimum level of knowledge of a subject area that students are assumed to have acquired through previous study. It is the responsibility of students to ensure they meet the assumed knowledge expectations of the subject. Students who do not possess this prior knowledge are strongly recommended against enrolling and do so at their own risk. No concessions will be made for students’ lack of prior knowledge.
Juris Doctor students are expected to have completed a minimum of 80 credit points of compulsory law subjects.
Must be admitted into a Masters Law degree OR LA-43040 Doctor of Legal Science (Research) OR be an approved Law Study Abroad or Law Exchange student.
This subject is not available as a general elective. To be eligible for enrolment, the subject must be specified in the students’ program structure.
Assurance of learning
Assurance of Learning means that universities take responsibility for creating, monitoring and updating curriculum, teaching and assessment so that students graduate with the knowledge, skills and attributes they need for employability and/or further study.
At Bond University, we carefully develop subject and program outcomes to ensure that student learning in each subject contributes to the whole student experience. Students are encouraged to carefully read and consider subject and program outcomes as combined elements.
Program Learning Outcomes (PLOs)
Program Learning Outcomes provide a broad and measurable set of standards that incorporate a range of knowledge and skills that will be achieved on completion of the program. If you are undertaking this subject as part of a degree program, you should refer to the relevant degree program outcomes and graduate attributes as they relate to this subject.
Subject Learning Outcomes (SLOs)
On successful completion of this subject the learner will be able to:
- Understand and apply the basic principles governing key areas of international business taxation.
- Gain unique insights into current high level decisions in the international tax arena through seminars where key players in international tax share their current international tax issues and ongoing practical application of tax strategy.
- Reflect on seminars and record their individual responses, demonstrating analysis and critical thinking.
- Showcase their initiative, critical thinking, analysis and writing skills as well as learning outcomes through the selection of a current international tax topic of their choice (after obtaining consent of the coordinator), writing a substantial individual publication standard paper on this topic.
|*Class Participation||Seminar attendance and participation||20%||Ongoing||1, 2.|
|Journal-Learning Log||Reflective Journal of 6,600 words, 600 words each reflection on the first 11 seminars. To be submitted on Monday 25 March 2019, week 12.||20%||Week 12||1, 2, 3.|
|*In-Class Quiz - Individual||Compulsory multiple choice open book quiz; Students will have the option of including their quiz mark OR writing an additional 1,000 words for their approved written assignment.||10%||Week 12||1.|
|Essay||Written Assessment - individual Taxation of International Business Topic - 5,000 words for postgraduate students. Please note: individual topics are to be selected by students, but these must be officially approved by the subject coordinator by Wednesday, of week 10 (20th March 2019) in order to be assessed. Assignments must be submitted by Thursday 11 April 2019, week 13.||50%||Week 13||1, 2, 4.|
- * Assessment timing is indicative of the week that the assessment is due or begins (where conducted over multiple weeks), and is based on the standard University academic calendar
- C = Students must reach a level of competency to successfully complete this assessment.
|High Distinction||85-100||Outstanding or exemplary performance in the following areas: interpretative ability; intellectual initiative in response to questions; mastery of the skills required by the subject, general levels of knowledge and analytic ability or clear thinking.|
|Distinction||75-84||Usually awarded to students whose performance goes well beyond the minimum requirements set for tasks required in assessment, and who perform well in most of the above areas.|
|Credit||65-74||Usually awarded to students whose performance is considered to go beyond the minimum requirements for work set for assessment. Assessable work is typically characterised by a strong performance in some of the capacities listed above.|
|Pass||50-64||Usually awarded to students whose performance meets the requirements set for work provided for assessment.|
|Fail||0-49||Usually awarded to students whose performance is not considered to meet the minimum requirements set for particular tasks. The fail grade may be a result of insufficient preparation, of inattention to assignment guidelines or lack of academic ability. A frequent cause of failure is lack of attention to subject or assignment guidelines.|
For the purposes of quality assurance, Bond University conducts an evaluation process to measure and document student assessment as evidence of the extent to which program and subject learning outcomes are achieved. Some examples of student work will be retained for potential research and quality auditing purposes only. Any student work used will be treated confidentially and no student grades will be affected.
Students must check the [email protected] subject site for detailed assessment information and submission procedures.
Policy on late submission and extensions
A late penalty will be applied to all overdue assessment tasks unless an extension is granted by the subject coordinator. The standard penalty will be 10% of marks awarded to that assessment per day late with no assessment to be accepted seven days after the due date. Where a student is granted an extension, the penalty of 10% per day late starts from the new due date.
Policy on plagiarism
University’s Academic Integrity Policy defines plagiarism as the act of misrepresenting as one’s own original work: another’s ideas, interpretations, words, or creative works; and/or one’s own previous ideas, interpretations, words, or creative work without acknowledging that it was used previously (i.e., self-plagiarism). The University considers the act of plagiarising to be a breach of the Student Conduct Code and, therefore, subject to the Discipline Regulations which provide for a range of penalties including the reduction of marks or grades, fines and suspension from the University.
Feedback on assessment
Feedback on assessment will be provided to students within two weeks of the assessment submission due date, as per the Assessment Policy.
If you have a disability, illness, injury or health condition that impacts your capacity to complete studies, exams or assessment tasks, it is important you let us know your special requirements, early in the semester. Students will need to make an application for support and submit it with recent, comprehensive documentation at an appointment with a Disability Officer. Students with a disability are encouraged to contact the Disability Office at the earliest possible time, to meet staff and learn about the services available to meet your specific needs. Please note that late notification or failure to disclose your disability can be to your disadvantage as the University cannot guarantee support under such circumstances.
The importance of tax considerations in International Business. Key issues: The Global marketplace; Globalisation; The Multinational Enterprise; Tax systems are based on Sovereignty
Understanding Double Tax Agreements; The Singapore-Australia DTA; The OECD Model; Methods for the Elimination of Double Taxation; Function of DTAs; Mutual Agreement Procedure; Key principles used in Agreements.
Guest speaker on Tax Treaties; the OECD's BEPS Action Plan and its impact on Tax Treaties.
The importance of Transfer Pricing in the 21st century; What is Transfer Pricing.
The need for an increased focus on APAs to resolve issues arising out of international transfer pricing.
Guest speakers on Transfer Pricing; Unilateral, bilateral and multilateral agreements; advantages and disadvantages.
Guest speakers on APAs; Interactive questions on weeks 1-6.
CFC rules; Application of the CFC regime; unlisted & listed country CFCs; FITOs; Thin capitalisation debt/equity rules.
A consideration of recent tax haven issues.
Guest speakers on CFCs and thin capitalisation; The Global Forum on Transparency and Exchange of Information for Tax Purposes.
Guest speaker on Tax Havens; assessment tips.
Quiz in class, and evaluation of quiz answers; final wrap-up.