DI170 International Tax Law & Policy

Despite an extensive network of tax treaties (more than 3000 tax treaties are in force worldwide), tax law has often been viewed as part of domestic - rather than international - law. However, this is changing: international tax law is quickly emerging as a key area of international economic law. International taxation, like trade, has major social, environmental and economic implications. International tax law does not only affect the ability of states to finance their public goods and services, it also shapes the relationship between citizens and the states. For example, citizens might lose trust in the state when the international tax regime allows multinational corporations and mobile citizens to avoid and evade taxes.

This course introduces students to international tax law, including (a) the history of the international tax regime, (b) its institutions, (c) the concepts of tax sovereignty, nexus, source, residence, tax competition, (d) the sources of international tax law, with an emphasis on double tax treaties, (e) new international tax institutions and agreements (the inclusive framework, the multilateral instrument). This course also explores the linkages between international tax law and general principles of international law. This course is designed to be accessible to students (in law and other disciplines) who might not yet be familiar with tax law concepts.