The problem of the Norwegian courses “Skatterett I/ Tax Law I” and “Skatterett II/
Tax Law II” is that they hardly take into account Norway's relations to the rest of ...
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Prof. Dr Rainer Zielke Professor in Business Economics with special reference to international taxation
Faculty of Business, Languages and Social Sciences
Østfold University College, NO-1757 Halden, Norway Tel. (0047) 69 21 - 52 93, E-mail:
[email protected] Homepage: www.fag.hiof.no/~rainerz Halden, 21 October 2014
Draft to a new course within a planned new master degree in economics and administration:
International Business Taxation – Master course description – Lecturer: Professor Dr Rainer Zielke Language: English Amount of hours: 52 Exam: 4 hours individual exam The Faculty of Business, Languages and Social Sciences is in the process of developing a new master degree in economics and administration where Rainer Zielke will teach “International Business Taxation”. Once established we will possibly be about to develop a constructive Ph.D. programme in “Economics and Administration and Organisation and Leadership” at Østfold University College which will replace the individual case solutions of Ph.D. graduations supervised by Rainer Zielke. The problem of the Norwegian courses “Skatterett I/ Tax Law I” and “Skatterett II/ Tax Law II” is that they hardly take into account Norway’s relations to the rest of the world. But we are connected to nearly all other countries with international business relations, and double taxation conventions are concluded frequently. Especially multinational groups of affiliated corporations have to consider the international tax differential in order to reduce the groups Effective Tax Rate (ETR). Internationally operating corporations and auditing companies are searching for specialists in International Business Taxation. The course described as follows closes this gap and is unique in Norway: Contents of the course: 1. Introduction 2. Norway’s International Business Taxation 2.1 Overview on Norwegian tax law 2.2 Norwegian investments abroad 2.3 Foreign investments in Norway 2.4 Norway’s relation to the EU concerning European tax law on direct taxation 3. The law of double taxation conventions 3.1 Introduction to the OECD Model Convention 3.2 Persons covered 3.3 Taxes covered 3.4 Allocation rules 3.5 Methods for elimination of double taxation 4. International tax planning in a group of affiliated corporations 4.1 Objectives and concepts for international tax planning 4.2 Anti-avoidance legislation 4.3 International tax planning strategies such as transfer pricing 4.4 Usage of international tax law databases Learning objectives: To have the knowledge of and the ability to apply the principles of International Business Taxation as outlined in the contents above. Literature: Zimmer, Fredrik, Internasjonal inntektsskatterett, 2009, 4th edition, Universitetsforlaget Oslo. Lang, Michael et al. (ed.), Introduction to European Tax Law on Direct Taxation, 2010, Linde Verlag Wien, IBFD Amsterdam. Lang, Michael, Introduction to the Law of Double Taxation Conventions, 2013, Linde Verlag Wien/ IBFD Amsterdam. Zielke, Rainer, International Tax Planning with Tax Havens – Objectives and Strategies in a Multinational Group of Affiliated Corporations, Bulletin for International Taxation, 2011, pp. 80-87 (comment: only the examples refer to tax havens, the article outlines the principles of international tax planning).
