International Taxation 2600-0550211003

1.Introduction. International Tax Law and International Double Taxation Law.
1.1. Concepts.
1.2. Basic Legal Issues.

2.International Double Taxation. Types, Measures and Methods of its avoidance.
2.1. Economic Double Taxation vs. Legal Double Taxation.
2.2. Unilateral, Bilateral and Multilateral Measures.
2.3. Exemption Method and Tax Credit Method.
2.3.1. Full Exemption vs. Exemption with Progression.
2.3.2. Ordinary Tax Credit vs. Full Tax Credit.
2.3.3. Per-Income Limitation and Per-Country Limitation.

3. Model Double Taxation Conventions (OECD, UN, US).
3.1. OECD Model Double Taxation Convention. Concept and Development
(1963, 1977, 1992-onwards). Detailed Structure.
3.2. UN and US Model Double Taxation Conventions. Brief Overview.
3.3. Source Country vs. Residence Country. Unlimited and Limited Tax Liability. Scope of Application of Double Taxation Treaties and Determination of the Residence for International Taxation Purposes.
3.3. Permanent Establishment and Taxation of Business profits. Concepts
and Consequences in the Bilateral Double Taxation Treaties.
3.4. General Concept of Cross-Border Taxation of "Passive Income". Taxation of Cross-Border Payments of Dividends, Interest and Royalty Payments under Polish Tax Law and Bilateral Double Taxation Treaties. Taxation of Cross-Border Leasing Payments.
3.5. Taxation of International Capital Gains.
3.6. International Taxation of Dependent Services and Directors' Fees.
3.7. International Taxation of Associated Enterprises and International Transfer Pricing Issues.
3.8. Taxation of so-called "Other Income".
3.9. Entry into Force vs. Effective Date of the Bilateral Double Taxation Treaty.

4. Tax Havens.
4.1. Characteristcs of Tax Havens and their Treatment under International Tax Law. Selected Examples
4.2. Advantages and Disadvantages of Using Tax Havens. OECD's "Black List" vs. Poland's Black List.

5. Other International Taxation Issues.