| Week | Subjects | Related Preperation |
| 1 |
International tax policy |
Recommended reading: Holmes Kevin, International Tax Policy and Double Tax Treaties, An Introduction to Principles and Application, IBFD, 2007 (Chapter 1). |
| 2 |
Overview of international tax treaties, Concept of double taxation, General structure of double tax treaties, Interpretation of double tax treaties, Scope of application of double tax treaties |
Recommended reading: Holmes Kevin, International Tax Policy and Double Tax Treaties, An Introduction to Principles and Application, IBFD, 2007 (Chapters 2, 3, 4, 5, 7). Engelen Frank, Interpretation of Tax Treaties under International Law, p. 425-520. |
| 3 |
Methods for elimination of double taxation Concept of ‘residence’ |
Required reading: Holmes Kevin, International Tax Policy and Double Tax Treaties, An Introduction to Principles and Application, IBFD, 2007 (Chapter 6); Recommended reading: Holmes Kevin, International Tax Policy and Double Tax Treaties, An Introduction to Principles and Application, IBFD, 2007 (Chapter 8). |
| 4 |
Concept of ‘permanent establishment’ |
Reading Requirement: Holmes Kevin, International Tax Policy and Double Tax Treaties, An Introduction to Principles and Application, IBFD, 2007 (Chapter 9). Recommended reading: Sasseville Jacques/Skaar Arvid A., Is there a permanent establishment? General Report in IFA Cahiers 2009, Volume 94A, p. 17ff; OECD Commentary, Article 5. |
| 5 |
Introduction to distributive rules Allocation of business profits |
Reading Requirement: Holmes Kevin, International Tax Policy and Double Tax Treaties, An Introduction to Principles and Application, IBFD, 2007 (Chapter 10). Recommended Reading: OECD Commentary, Article 7 |
| 6 |
Taxation of business profits deriving from ‘e-commerce’ and ‘sharing economy’ |
Recommended reading: Hongler Peter/Pistone Pasquale, Blueprints for a new PE nexus to tax business income in the era of digital economy, IBDF Working Paper, 2015; Bal Aleksandra, The Sky’s the Limit – Cloud-Based Services in an International Perspective, Bulletin for International Taxation, September 2014, p. 515ff. |
| 7 |
Midterm |
|
| 8 |
Transfer Pricing |
Reading Requirement: Holmes Kevin, International Tax Policy and Double Tax Treaties, An Introduction to Principles and Application, IBFD, 2007 (Chapter 11). Recommended reading: OECD Commentary, Article 9. |
| 9 |
Transfer Pricing Taxation of dividends, interests, royalties and technical services fees |
Recommended reading: Holmes Kevin, International Tax Policy and Double Tax Treaties, An Introduction to Principles and Application, IBFD, 2007 (Chapters 12, 13, 14); OECD Commentary, Articles 10, 11 and 12. |
| 10 |
Taxation of immovable property, Taxation of capital gains, Taxation of personal services, Other distributive rules |
Reading requirement: Holmes Kevin, International Tax Policy and Double Tax Treaties, An Introduction to Principles and Application, IBFD, 2007 (Chapters 15, 16, 17); Recommended reading: Holmes Kevin, International Tax Policy and Double Tax Treaties, An Introduction to Principles and Application, IBFD, 2007 (Chapter 18). |
| 11 |
Taxation of entertainers and sportspersons Taxation of international sports events |
Recommended reading: Sandler Daniel, Artistes and Sportsmen (Article 17 of the OECD Model Convention) in Lang et al. (eds), Source versus Residence: Problems Arising from the Allocation of Taxing Rights in Tax Treaty Law and Possible Alternatives, London, 2008, p. 215ff; Yazıcıoğlu Alara Efsun, Draft Guide On the Taxation of Professional Sports Clubs and Players issued, A very promising starting p |
| 12 |
Exchange of information, Principle of non-discrimination, Arbitration and Mutual Agreement Procedure |
Recommended reading: Course notes; OECD Commentary, Articles 24, 25 and 26. |
| 13 |
Treaty shopping, Treaty abuse |
Recommended reading: Course notes. |
| 14 |
Tax structuring: most commonly used structures |
None. |
At Kadir Has University, a Semester is 14 weeks; The weeks 15 and 16 are reserved for final exams.
THE RELATIONSHIP BETWEEN COURSE LEARNING OUTCOMES (LO) AND PROGRAM QUALIFICATIONS (PQ)
| # |
PQ1 |
PQ2 |
PQ3 |
PQ4 |
PQ5 |
PQ6 |
PQ7 |
PQ8 |
PQ9 |
PQ10 |
| LO1 |
3 |
3 |
2 |
2 |
3 |
3 |
2 |
3 |
2 |
2 |
| LO2 |
3 |
3 |
2 |
2 |
3 |
3 |
2 |
3 |
2 |
2 |
| LO3 |
3 |
3 |
2 |
2 |
3 |
3 |
2 |
3 |
2 |
2 |
| LO4 |
3 |
3 |
2 |
2 |
3 |
3 |
2 |
3 |
2 |
2 |
Contribution: 1 Low, 2 Average, 3 High
