International Tax Law WSE-EKN-ITLX

1. Introduction. International Tax Law and International Double Taxation Law.
1.1. Concepts.
1.2. Basic Legal Issues.
1.3. Taxation of artists, freelancers and sport stars
2. International Double Taxation. Types, Measures and Methods of its avoidance.
2.1. Economic Double Taxation vs. Legal Double Taxa-tion.
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. International tax strategies
4. Model Double Taxation Conventions (OECD, UN, US).
4.1. Source Country vs. Residence Country. Unlimited and Limited Tax Liability. Scope of Application of Double Taxa-tion Treaties and Determination of the Residence for Interna-tional Taxation Purposes.
4.2. Permanent Establishment and Taxation of Business profits. Concepts and Consequences in the Bilateral Double Taxation Treaties.
4.3. General Concept of Cross-Border Taxation of “Pas-sive Income”. Taxation of Cross-Border Payments of Divi-dends, Interest and Royalty Payments under Polish Tax Law and Bilateral Double Taxation Treaties. Taxation of Cross-Border Leasing Payments.
4.4. Taxation of International Capital Gains.
4.5. International Taxation of Dependent Services and Directors’ Fees.
4.6. International Taxation of Associated Enterprises and International Transfer Pricing Issues.
4.7. Taxation of so-called “Other Income”.
4.8 Entry into Force vs. Effective Date of the Bilateral Double Taxation Treaty.
4. Tax Havens.
4.1. Characteristics of Tax Havens and their Treatment under International Tax Law.
4.2. Advantages and Disadvantages of Using Tax Havens.
4.3. Tax havens in practice
5. Other International Taxation Issues.