TABL5508 International Tax: Anti-Avoidance

Subject Code

TABL5508

Study Level

Postgraduate

Commencing Term

Term 3

Total Units of Credit (UOC)

Delivery Mode

Online

School

Accounting Auditing & Tax

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The course outline is not available for current term. To view outlines from other years and/or terms, visit the archives .

1. Course Details

Given the ongoing COVID-19 restrictions in NSW, all Term 3 courses will be delivered online until at least Friday 22nd October and all assessment will be online throughout the term. The University remains hopeful that the situation will improve to allow for some on-campus activities later in Term 3 such as lab, practical and studio classes. UNSW will continue to review the situation regularly and keep students updated. For further information on how your study may be affected this term, please see FAQs here. See tab 8. Policies and Support in this course outline for tips on online study and assessment.

Summary of Course

International Taxation comprises a complex body of learning which is relevant to any cross border event whether that be in the form of cross border investment or cross border movement of people.

This course exposes participants to the main aspects of the law which are relevant specifically to Anti avoidance of international taxation. The areas covered need to be clearly understood by anyone dealing with cross border income flows in order to avoid inadvertently falling into an unexpected trap created by these provisions.

In these materials, both Income Tax Assessment Act 1936 (‘ITAA36’) and the Income Tax Assessment Act 1997 (‘ITAA97’) have been referred to as the ‘Act’ or ’ITAA’. Generally, references to unhyphenated sections are to the relevant sections of the ITAA36. References to hyphenated sections (e.g., s 104–20) are to relevant sections of the ITAA97.

The study guide for International Taxation: Anti-avoidance comprises 10 modules:

Overview of the BEPS Project and its impact
CFC’s, control and attributable taxpayers
Active income test
CFC—attributable income
Dividends, exemptions and foreign income tax offsets
Second tier CFC provisions and deemed dividends
Non-resident trusts Other anti-avoidance measure
Thin Capitalisation and Transfer Pricing
The MAAL and the Diverted Profits Tax
Hybrid Mismatch Provisions

Teaching Times and Locations

Please note that teaching times and locations are subject to change. Students are strongly advised to refer to the Class Timetable website for the most up-to-date teaching times and locations.

View course timetable

Course Policies & Support

The Business School expects that you are familiar with the contents of this course outline and the UNSW and Business School learning expectations, rules, policies and support services as listed below:

Program Learning Outcomes
Academic Integrity and Plagiarism
Student Responsibilities and Conduct
Special Consideration
Protocol for Viewing Final Exam Scripts
Student Learning Support Services

Further information is provided in the Assessment and Policies and Support sections.

Students may not circulate or post online any course materials such as handouts, exams, syllabi or similar resources from their courses without the written permission of their instructor.

Course Aims and Relationship to Other Courses

On successful completion of this course, students will be able to:

Demonstrate an understanding of the basics of the attribution (Controlled Foreign Corporations and Transferor Trusts), thin capitalisation, and transfer pricing measures, multinational anti avoidance law, diverted profits tax, and hybrid mismatch rules.
Apply the attribution rules, focusing on concepts of control, active income and methods of attribution.
Conduct international comparisons of anti-avoidance measures.

This course is one of the foundation courses in the International Taxation stream of the Master of Taxation postgraduate program. The full suite of International Taxation courses includes the following:

TABL5504 Asia Pacific Tax Regimes
TABL5508 International Taxation: Anti-avoidance (this course)
TABL5520 Principles of Australian International Taxation
TABL5526 Taxation and Investment Regulation in China
TABL5528 International Taxation: Design and Structure
TABL5537 Double Tax Agreements
TABL5534 Specific Tax Jurisdictions: Europe
TABL5535 Specific Tax Jurisdictions: North America
TABL5581 International Tax Research

This course follows on from TABL5520 Principles of Australian International Taxation which deals with basic principles of international taxation.

Student Learning Outcomes

The Course Learning Outcomes (CLOs) are what you should be able to demonstrate by the end of this course, if you participate fully in learning activities and successfully complete the assessment items.

CLOs also contribute to your achievement of the Program Learning Outcomes (PLOs), which are developed across the duration of a program for all coursework students in the Business School. More information on PLOs is available under Policies and Support. PLOs are, in turn, directly linked to UNSW graduate capabilities and the aspiration to develop “globally focussed graduates who are rigorous scholars, capable of leadership and professional practice in an international community”.

The following table shows how the CLOs for this course relate to the overall PLOs and indicates where each CLO and PLO is assessed:

Course Learning Outcomes	Program Learning Outcomes	Course Assessment Item
On successful completion of the course, you should be able to:	This course helps you to develop the following Program Learning Outcomes:	This learning outcome will be assessed in the following items:
Understand the main aspects of the law relevant specifically to preventing avoidance of taxpayer obligations in respect of Australia’s international taxation jurisdiction. Apply this knowledge in dealing with practical scenarios involving cross border income flows.	PLO 1: Business knowledge PLO 2: Problem solving	Online Quiz Research Paper Final Exam
Apply the rules relating to attribution, thin capitalisation, and transfer pricing in a variety of factual situations.	PLO 1: Business knowledge PLO 2: Problem solving	Online Quiz Research Paper Final Exam
Demonstrate a critical approach to material presented and evidence of original and independent thought.	PLO 1: Business knowledge PLO 2: Problem solving PLO 3: Business communication	Online Quiz Research Paper Final Exam
Demonstrate an ability to locate appropriate and relevant sources, and to effectively analyse and apply these sources in the construction of legal argument.	PLO 1: Business knowledge PLO 2: Problem solving PLO 5: Responsible business practice PLO 6: Global and cultural competence	Online Quiz Research Paper Final Exam
Recognise and resolve legal and tax problems.	PLO 1: Business knowledge PLO 2: Problem solving	Online Quiz Research Paper Final Exam
Develop clear, effective and well-reasoned analysis of the tax consequences of practical scenarios using the conventions of legal essay writing.	PLO 1: Business knowledge PLO 2: Problem solving PLO 3: Business communication PLO 6: Global and cultural competence	Research Paper Final Exam
Apply correct citation and referencing conventions in properly acknowledging all source material used.	PLO 1: Business knowledge PLO 2: Problem solving PLO 3: Business communication	Research Paper Final Exam
Demonstrate a practical understanding of the impact of anti-avoidance measures on cross border income flows.	PLO 2: Problem solving PLO 3: Business communication PLO 5: Responsible business practice	Online Quiz Research Paper Final Exam
Demonstrate the ability to make comparison between the anti-avoidance measures adopted in various international jurisdictions.	PLO 1: Business knowledge PLO 3: Business communication PLO 5: Responsible business practice PLO 6: Global and cultural competence	Online Quiz Research Paper Final Exam

2. Staff Contact Details

Position	Title	Name	Email	Location	Phone	Consultation Times
Lecturer-in-charge	Prof	Robert Deutsch		–	+61 438 043 833	By appointment, email preferred.

Communication with staff

When you contact staff by email, please:

Use your University (not personal) email address
Specify the course TABL5508 as appropriate; and
Sign off by using your name and student identity number

3. Learning and Teaching Activities

Approach to Learning and Teaching in the Course

How to Use These Study Materials

If you are new to flexible learning you should carefully read this Course Outline. It contains most of the relevant information about how this course will be run and the expectations of you as a student. You should also refer to the suggested study Schedule as a guide to completing your coursework. To get the most out of your study we recommend that you follow this study schedule through the course and fit various time demands into a well-organised diary. Systematic study through the term is the key to success in a flexible learning program.

The Study Guide (which includes this Course Outline and the individual Modules and is sometimes referred to as the study materials or course materials) can help you in three ways.

It sets out a clear path of study over the term and helps you plan your workload. It also identifies learning outcomes and key concepts at the start of each module and provides a series of activities to help you learn actively and manage your own progress through the course.
It contains the core content for the course (often with reference to legislation, textbooks and other relevant material). The structure and layout of the Study Guide is designed to highlight key points and assist your revision for assignments, research papers and examinations.
It tells you when to refer to textbooks, legislation and other readings, giving precise details of what you should read.

Features of the Study Guide

Each module includes a range of features to assist you in managing your learning and developing study skills. These features include:

Overview page
Heading levels
Learning outcomes and key concepts
Module text
Activities and feedback
Readings
Margin notes
Instructional icons

Audio Conferences

Throughout this course you will have the opportunity to attend live audio conferences (conducted via phone). Instructions on preparing for and participating in audio conferences are available on your course Moodle website.

These audio conferences provide an opportunity for you to clarify and extend your understanding of the material in this course. They are designed to try out new ideas and give you a forum to ask questions and discuss issues with your lecturer and other students. Do not be afraid to participate—it is only by trying out new ideas and exploring their dimensions that you will learn in any real depth.

Thorough preparation is essential if you are to gain maximum benefit from an audio conference. You can only start to come to grips with material if you work on it actively. As a general rule each audio conference will cover the module/s between the previous audio conference and the week it falls within on the suggested study Schedule. However, more specific information on material to be covered in each audio conference may be provided via Moodle throughout the term. Exact dates and times for audio conferences will be advised via a timetable that you will find on Moodle.

There are five audio conferences scheduled for this course during the Term. Each audio conference is of approximately one and a half hours duration.

Remember audio conferences are not lectures—your active participation is an important part of the learning experience and preparation for examinations!

Learning Activities and Teaching Strategies

This course uses review activities within the learning materials and tutorial questions within the audio conferences. The learning materials are the lectures and must be studied. These are supplemented by online resources including on-line quizzes.

The assignments and examination test understanding and develop skills of communication, both written and oral.

The audio conferences develop oral communication and group work skills.

4. Assessment

Formal Requirements

In order to pass this course, you must:

achieve a composite mark of at least 50 out of 100;
meet any additional requirements described in the Assessment Summary section.

You are expected to attempt all assessment requirements in the course.

Assessment Structure

Assessment Task	Weighting	Length	Due Date
Research Plan.	10%	–	Week 3: 11.59pm Wednesday 29 September.
Online Quiz 1.	5%	–	Week 5: During the week commencing 11 October with submission no later than 11.59pm 15 October.
Research Paper.	40%	–	Week 8: 11.59pm Wednesday 3 November.
Online Quiz 2.	5%	–	Week 9: During the week commencing 8 November with submission no later than 11.59pm on 12 November.
Take Home Exam.	40%	–	UNSW Examination Period.
Total	100%	–	–

Assessment Summary

As a student at UNSW you are expected to display academic integrity in your work and interactions. Where a student breaches the UNSW Student Code with respect to academic integrity, the University may take disciplinary action under the Student Misconduct Procedure. To assure academic integrity, you may be required to demonstrate reasoning, research and the process of constructing work submitted for assessment.

To assist you in understanding what academic integrity means, and how to ensure that you do comply with the UNSW Student Code, it is strongly recommended that you complete the Working with Academic Integrity module before submitting your first assessment task. It is a free, online self-paced Moodle module that should take about one hour to complete.

On-line quizzes

Students will required to answer 2 on-line quizzes each worth 5%. The on-line quizzes will be placed on Moodle.at the beginning of the week in which answers to the quizzes are due for submission.

Take Home Exam

The final assessment for this course will be a take-home exam which will be made available on Moodle during the University exam period. The release dates for provisional and final exam timetables are listed on the University's Key Dates for Exams page.

The exam timetable is released via myUNSW and is personalised for each student. You must view your personal timetable and note the time and date that appears on myUNSW. Your exam timetable is published on myUNSW in April for Term 1, July for Term 2, and November for Term 3.

You should check this timetable to find the dates of your take-home exams. This is not a negotiable schedule.

Exams will be released at 9am at regular intervals throughout the exam period. Submissions are due at 7am on the third day after the release date. For example, an exam released at 9am on 7 November will be due at 7am on 10 November. All times are based on Sydney time.

Exams are not assignments. Abbreviated referencing may be used. No bibliography is needed but normal writing conventions (such as no plagiarism) must be observed. Word length must be observed.

Submissions will be made online through a Turnitin submission link on Moodle. Students will be permitted to use a range of resources and materials to prepare responses. Students will be required to state that they have not consulted any other person in relation to the content of the exam or responses to questions during the date of the exam's release on Moodle and the closing time for submissions of responses via Turnitin.

Students will only have one opportunity to submit (i.e. no resubmission of drafts) and no late submissions will be accepted.

For information on studying and preparing for a take home exam.

Assessment Format

The following guidelines are offered as a general indication of what is expected in terms of the presentation of both assignments and research papers in flexible distance (Atax) courses.

Each assessment task may also have particular requirements not covered here. Where information here is in conflict with information provided by the course lecturer, you should follow the advice of your lecturer.

Assignment cover sheets

You must ensure that you include a cover page with each of your assignments that has the following information:

your name
your student ID
the course code
the course name
the due date
number of words

You should also include your name, ID and course code in the footer of your assignment document along with page numbers. A sample cover sheet can be found on Moodle in the Assessments section.

Abstract

An abstract is used to summarise the subject of a research paper. Abstracts are only required for research papers and should contain 100 to 200 words. Do not write an abstract for a problem-type assignment.

Margins

You should allow the following standard margins in your assignments to allow space for the lecturer’s comments: Left and right margins — 3.5 cm; Top and bottom margins — 2.5 cm.

Headings/Table of contents

Headings should be typed in bold. Only capitalise the first letter of the heading. Do not capitalise the entire heading. If you have written a long essay with many parts, a table of contents should be used. Otherwise, do not include one.

Style of presentation

Your assignment should be typed using an 11 or 12 point font. Single line spacing should normally be used, unless your lecturer tells you otherwise. Leave a line after each paragraph. Do not indent the first line of the paragraph. You should number each page of the assignment.

Footnotes and citation system

You should use footnotes as your referencing tool. Use end notes only if your computer cannot produce footnotes. Use the rules set out in a recognised citation and style guide such as the Australian Guide to Legal Citation. Footnotes are not normally included in the word limit, unless you include substantial commentary or discussion in the footnotes.

Bibliography

Details of works cited in the text are provided in a bibliography which is placed at the end of the document on a new page under the heading ‘Bibliography’. The bibliography is not included in the word limit.

All publications (books, articles, theses etc.) are included in the bibliography. Legal cases and legislation are not included in the bibliography. If a list of cases is considered necessary due to the large number used, it should be in alphabetical order under a separate heading ‘Legal cases’. A similar separate list, headed ‘Legislation’, is used if needed for legislation.

Your bibliography must be presented in the following format:

Items in the bibliography are listed alphabetically by author or source.
The citation style of the item should be in accordance with a recognised and appropriate citation and style guide, except that specific page references are not included.

Assignment Submission Procedure

Assignment submissions and deadlines

This course uses UNSW Moodle for the electronic delivery and submission of assignments.

Please check your submission link – you may only be entitled to submit an assignment once in which case additional and subsequent submissions will not be accepted.

Step-by-step guides have been produced to assist students through the assignment submission process, and are available for download from the UNSW Teaching Gateway.

Due date and time

Each assignment should be submitted via Moodle by 23:59 AEST (or AEDT, Australian Eastern Daylight Time, where applicable) on the specified due date unless otherwise stipulated. You are advised to submit your assignment early if possible, and to allow at least 15 minutes for the Moodle submission process. Most assignments will be parsed through Turnitin which will check the originality of your work. If you are given the opportunity to resubmit your assignment up until the due date you should be aware that even though you can submit more than once each day, Turnitin will only produce one originality report every 24 hours so there may be a delay on receiving your updated originality report after the first submission. The version of your assignment that is submitted at the due date will be the version that is accepted for marking. Check for information on submitting assignments via Turnitin and interpreting originality reports.

Name and save your assignment documents

For identification purposes you are required to name all of your assignment files that you are submitting using the following naming convention:

Surname_GivenName_Course Code format.

For example: ‘Lawson_Henry_TABL1001As1.doc’

You must retain a copy of every assignment. No mark can be given or concession awarded should an assignment be lost and no evidence of completion is able to be provided by the student.

Problems with Moodle assignment submission

If you encounter technical difficulties while attempting to access Moodle, and are unable to submit your assignment, please contact the IT Service Desk by email to ITServiceCentre@unsw.edu.au or by telephone on +61 (2) 9385 1333. Your lecturer will not be able to assist with assignment submission issues, and cannot accept assignments emailed direct to him/her.

Assignment return

Assignments will be marked electronically. Feedback for assignments will be made available electronically, usually through Moodle. Lecturers will make every effort to return assignments (which are submitted on time) within two weeks with appropriate comments and feedback.

Assessment Feedback

Feedback on student performance from formative and summative assessment tasks will be provided to students in a timely manner. Assessment tasks completed within the teaching period of a course, other than a final assessment, will be assessed and students provided with feedback, with or without a provisional result, within 10 working days of submission, under normal circumstances. Feedback on continuous assessment tasks (e.g. laboratory and studio-based, workplace-based, weekly quizzes) will be provided prior to the midpoint of the course.

Special Consideration

You can apply for special consideration when illness or other circumstances beyond your control interfere with your performance in a specific assessment task or tasks, including online exams. Special consideration is primarily intended to provide you with an extra opportunity to demonstrate the level of performance of which you are capable. To apply, and for further information, see Special Consideration on the UNSW Current Students page.

Special consideration applications will be assessed centrally by the Case Review Team, who will update the online application with the outcome and add any relevant comments. The change to the status of the application immediately sends an email to the student and to the assessor with the outcome of the application.

Please note the following:

Applications can only be made through Online Services in myUNSW. Applications will not be accepted by teaching staff. The lecturer-in-charge/course coordinator will be automatically notified when your application is processed.
Applying for special consideration does not automatically mean that you will be granted a supplementary exam or other concession.
If you experience illness or misadventure in the lead up to an exam or assessment, you must submit an application for special consideration, either prior to the examination taking place, or prior to the assessment submission deadline, except where illness or misadventure prevent you from doing so.
If your circumstances stop you from applying before your exam or assessment due date, you must apply within 3 working days of the assessment or the period covered by your supporting documentation.
Under the UNSW Fit To Sit/Submit rule, if you sit the exam/ submit an assignment, you are declaring yourself well enough to do so and are cannot subsequently apply for special consideration.
If you become unwell on the day of – or during – an exam, you must stop working on your exam, advise your course coordinator or tutor and provide a medical certificate dated within 24 hours of the exam, with your special consideration application. For online exams, you must contact your course coordinator or tutor immediately via email, Moodle or chat and advise them you are unwell and submit screenshots of your conversation along with your medical certificate and application.
If your online assessment is scheduled at a specific time in Sydney, Australian Eastern Standard Time (AEST), you must make yourself available at the time advised. Special consideration will not be awarded on the grounds that you are in a different time zone.
Special consideration requests do not allow the awarding of additional marks to students.

Further information on Business School policy and procedure can be found under “Special Consideration” on the Policies and Support page.

Late Submission and Penalties

An assignment is not considered to be late if it has been submitted via Moodle on or before the due time and date. Posted, faxed or e-mailed assignments will NOT be marked and should not be sent.

If you submit an assignment after the due date, please be aware that the following penalties will be applied.

Where assignments are up to one week (i.e. 1–5 working days) late: 10% of the maximum marks available for the assessment item will be deducted.
Where assignments are more than one week late and up to two weeks (i.e. 6–10 working days) late: 20% of the maximum marks available for the assessment item will be deducted.
Where assignments are more than two weeks (i.e. 11 or more working days) late: the assignment can be perused, but no marks will be awarded. Assignments will be recorded only as having been submitted.

Please note that the penalties are applied to the maximum marks available for the assignment, not the actual mark awarded. For example, a student is due to submit an assignment by 8 October 2021. The assignment is in fact submitted on 22 October 2021 (10 working days late).

The penalty for lateness will be 20% of the maximum marks for the assessment. If the student's mark before the imposition of the penalty was a credit mark of 65%, after taking the penalty into account this mark will fall to 45%—a failure.

If illness or other verified circumstances beyond your control have a significant effect on your ability to submit an assignment by the due date, the normal penalty may be remitted. Doctor's reasons must be sufficiently detailed and specifically address the effect of the medical condition on your ability to complete assignments. For information on applying for penalty remissions through myUNSW Special Consideration portal, please visit: https://www.business.unsw.edu.au/about/schools/taxation-business-law/student-support/penalty-remissions

General points

Requests for penalty remissions are centrally managed by Student Lifecycle. Lecturers are not permitted to grant penalty remissions and you should not approach lecturers for this purpose.
You should not anticipate that a Penalty Remission will be granted, and should endeavour to submit all assignments as soon as possible.
If you require academic assistance contact your LiC and/or visit Student Support during the period that you are preparing assignments.
You have only 10 weeks in the term, during which time all assignments must be completed. You also need to prepare for the final examination in all courses. Therefore, your time management is very important.

The following is very important:

If your assignment is up to one week (i.e. 1–5 working days) late, your penalty remission request must clearly show that you are seeking a one week penalty remission and you must clearly state your reasons and provide all relevant documentation. If your reasons are judged insufficient you will receive no remission of penalty.

If your assignment is more than one week late but less than two weeks (i.e. 6–10 working days) late, your penalty remission request should indicate whether you are seeking a 10% or a 20% remission. You must clearly show why the penalty remission you are seeking is valid and provide all relevant documentation. If you have requested remission of a 20% penalty and your reasons are judged insufficient, you may receive either a 10% remission or no remission depending on the judged validity of your request. If you requested 10% and your reasons are judged insufficient you will receive no remission of penalty.

Protocol for Viewing Final Exam Scripts

UNSW students have the right to view their final exam scripts, subject to a small number of very specific exemptions. The UNSW Business School has set a protocol under which students may view their final exam script. Individual schools within the Faculty may also set up a local process for viewing final exam scripts, so it is important that you check with your School. Further school-specific information may be included below.

Students in the School of Accounting, Auditing and Taxation at the UNSW Business School are able to view their final examination script where they meet the conditions set out at https://www.business.unsw.edu.au/about/schools/accounting/student-support/viewing-final-examination-scripts.

Quality Assurance

The Business School is actively monitoring student learning and quality of the student experience in all its programs. A random selection of completed assessment tasks may be used for quality assurance, such as to determine the extent to which program learning goals are being achieved. The information is required for accreditation purposes, and aggregated findings will be used to inform changes aimed at improving the quality of Business School programs. All material used for such processes will be treated as confidential.

5. Course Resources

Prescribed text:

There are no prescribed textbooks for this course

Act/s:

You must purchase or have access to the following publication/s:

Income Tax Assessment Act 1936 and Regulations
Income Tax Assessment Act 1997

Citation and Style Guide:

In presenting written work for assessment in this course you must use an appropriate and consistent style for referencing and citation. The following is a selection of acceptable citation and style guides, which you may use as the basis for your written work. You must purchase or have access to one of the following publications.

Australian guide to legal citation (Melbourne University Law Review Association & Melbourne Journal of International Law).

(This is free to download and is the citation style guide used by the majority of Australian legal journals.)

Rozenberg P, Australian guide to uniform legal citation (Sydney: Lawbook Co, 2nd ed, 2003).
Stuhmcke A, Legal referencing (Sydney: LexisNexis, 4th ed, 2012).

Recommended References:

Woodley M (ed), Osborn’s Concise Law Dictionary (London: Sweet & Maxwell, 12th ed, 2013). This is the classic, concise dictionary of legal terms which is very useful for students of law based subjects.

For a comparative study on other jurisdictions, students may want to refer to the following:

Arnold B, The Taxation of Controlled Foreign Corporations: An International Comparison (Toronto: Canadian Tax Foundation, 1986).
Sandler D, Pushing the Boundaries: The Interaction between Tax Treaties and Controlled Foreign Company Legislation (London: Institute for Fiscal Studies, 1994).
OECD, Controlled Foreign Company Legislation (Paris: OECD, 1996).
Arnold B, ‘The Taxation of Investments in Passive Foreign Investment Funds in Australia, Canada, New Zealand and in the United States’, in Alpert & Van Raad (eds), Essays on International Taxation (Deventer: Kluwer, 1993).

Students may also wish to refer to relevant ATO publications on foreign income.

The readings in this course include extracts from Burns L, Controlled Foreign Companies (Melbourne: Longman Professional, 1992) and Hamilton RL, Deutsch RL & Raneri JC, Guidebook to Australian International Taxation (Sydney: LexisNexis Butterworths, Looseleaf Service, 2002). Please note that extracts from both of these publications should be read subject to any changes in the legislation that have occurred since their respective date of publication.

Electronic Databases:

The UNSW library subscribes to several electronic databases.

The website for this course is on Moodle.

6. Course Evaluation & Development

Feedback is regularly sought from students and continual improvements are made based on this feedback. At the end of this course, you will be asked to complete the myExperience survey, which provides a key source of student evaluative feedback. Your input into this quality enhancement process is extremely valuable in assisting us to meet the needs of our students and provide an effective and enriching learning experience. The results of all surveys are carefully considered and do lead to action towards enhancing educational quality.

The School of Accounting, Auditing & Taxation’s quality enhancement process involves regular review of its courses and study materials by content and educational specialists, combined with feedback from students.

The myExperience survey via Moodle will ask you to evaluate the effectiveness of your course lecturer and the actual course content. Your input into this quality enhancement process through the completion of this survey is extremely valuable in assisting us in meeting the needs of our students and in providing an effective and enriching learning experience.

7. Course Schedule

Note: for more information on the UNSW academic calendar and key dates including study period, exam, supplementary exam and result release, please visit: https://student.unsw.edu.au/new-calendar-dates

Week	Activity	Topic	Assessment/Other
Week 1: 13 September	Reading	Module 1:Overview of the BEPS Project and its impact.	–
Week 2: 20 September	Reading / Audio Conference	Module 2: CFCs, Control and Attributable Taxpayers.	Audio Conference 1.
Week 3: 27 September	Reading / Assignment	Module 3: Active Income Test.	Research Plan due: 11.59pm Wednesday 29 September.
Week 4: 5 October	Reading / Audio Conference	Module 4: CFCs – Attributable Income.	Audio Conference 2.
Week 5: 11 October	Reading / Online Quiz	Module 5: Dividends, Exemptions and Foreign Tax Credits.	Quiz 1: Online quiz on CFCs (modules 2 – 4).
Week 6: 18 October	Reading / Audio Conference	Module 6:Second Tier CFC Provisions and Deemed Dividends.	Audio Conference 3.
Week 7: 25 October	Reading	Module 7: Non-Resident Trusts.	–
Week 8: 1 November	Reading / Audio Conference	Module 8: Thin Capitalisation and Transfer Pricing.	Audio Conference 4. Research Paper due: 11.59pm Wednesday 3 November.
Week 9: 8 November	Reading / Online Quiz	Module 9: The MAAL and DPT.	Quiz 2: Online quiz on Thin Capitalisation and Transfer Pricing.
Week 10: 15 November	Reading / Audio Conference	Module 10: Hybrid Mismatch Provisions.	Audio Conference 5.

8. Policies and Support

Information about UNSW Business School program learning outcomes, academic integrity, student responsibilities and student support services. For information regarding special consideration and viewing final exam scripts, please go to the key policies and support page.

Program Learning Outcomes

The Business School places knowledge and capabilities at the core of its curriculum via seven Program Learning Outcomes (PLOs). These PLOs are systematically embedded and developed across the duration of all coursework programs in the Business School.

PLOs embody the knowledge, skills and capabilities that are taught, practised and assessed within each Business School program. They articulate what you should know and be able to do upon successful completion of your degree.

Upon graduation, you should have a high level of specialised business knowledge and capacity for responsible business thinking, underpinned by ethical professional practice. You should be able to harness, manage and communicate business information effectively and work collaboratively with others. You should be an experienced problem-solver and critical thinker, with a global perspective, cultural competence and the potential for innovative leadership.

All UNSW programs and courses are designed to assess the attainment of program and/or course level learning outcomes, as required by the UNSW Assessment Design Procedure. It is important that you become familiar with the Business School PLOs, as they constitute the framework which informs and shapes the components and assessments of the courses within your program of study.

PLO 1: Business knowledge

Students will make informed and effective selection and application of knowledge in a discipline or profession, in the contexts of local and global business.

PLO 2: Problem solving

Students will define and address business problems, and propose effective evidence-based solutions, through the application of rigorous analysis and critical thinking.

PLO 3: Business communication

Students will harness, manage and communicate business information effectively using multiple forms of communication across different channels.

PLO 4: Teamwork

Students will interact and collaborate effectively with others to achieve a common business purpose or fulfil a common business project, and reflect critically on the process and the outcomes.

PLO 5: Responsible business practice

Students will develop and be committed to responsible business thinking and approaches, which are underpinned by ethical professional practice and sustainability considerations.

PLO 6: Global and cultural competence

Students will be aware of business systems in the wider world and actively committed to recognise and respect the cultural norms, beliefs and values of others, and will apply this knowledge to interact, communicate and work effectively in diverse environments.

PLO 7: Leadership development

Students will develop the capacity to take initiative, encourage forward thinking and bring about innovation, while effectively influencing others to achieve desired results.

These PLOs relate to undergraduate and postgraduate coursework programs. For PG Research PLOs, including Master of Pre-Doctoral Business Studies, please refer to the UNSW HDR Learning Outcomes

Business School course outlines provide detailed information for students on how the course learning outcomes, learning activities, and assessment/s contribute to the development of Program Learning Outcomes.

UNSW Graduate Capabilities

The Business School PLOs also incorporate UNSW graduate capabilities, a set of generic abilities and skills that all students are expected to achieve by graduation. These capabilities articulate the University’s institutional values, as well as future employer expectations.

UNSW Graduate Capabilities	Business School PLOs
Scholars capable of independent and collaborative enquiry, rigorous in their analysis, critique and reflection, and able to innovate by applying their knowledge and skills to the solution of novel as well as routine problems.	PLO 1: Business knowledge PLO 2: Problem solving PLO 3: Business communication PLO 4: Teamwork PLO 7: Leadership development
Entrepreneurial leaders capable of initiating and embracing innovation and change, as well as engaging and enabling others to contribute to change	PLO 1: Business knowledge PLO 2: Problem solving PLO 3: Business communication PLO 4: Teamwork PLO 6: Global and cultural competence PLO 7: Leadership development
Professionals capable of ethical, self-directed practice and independent lifelong learning	PLO 1: Business knowledge PLO 2: Problem solving PLO 3: Business communication PLO 5: Responsible business practice
Global citizens who are culturally adept and capable of respecting diversity and acting in a socially just and responsible way.	PLO 1: Business knowledge PLO 2: Problem solving PLO 3: Business communication PLO 4: Teamwork PLO 5: Responsible business practice PLO 6: Global and cultural competence

While our programs are designed to provide coverage of all PLOs and graduate capabilities, they also provide you with a great deal of choice and flexibility. The Business School strongly advises you to choose a range of courses that assist your development against the seven PLOs and four graduate capabilities, and to keep a record of your achievements as part of your portfolio. You can use a portfolio as evidence in employment applications as well as a reference for work or further study. For support with selecting your courses contact the UNSW Business School Student Services team.

Academic Integrity and Plagiarism

Academic Integrity is honest and responsible scholarship. This form of ethical scholarship is highly valued at UNSW. Terms like Academic Integrity, misconduct, referencing, conventions, plagiarism, academic practices, citations and evidence based learning are all considered basic concepts that successful university students understand. Learning how to communicate original ideas, refer sources, work independently, and report results accurately and honestly are skills that you will be able to carry beyond your studies.

The definition of academic misconduct is broad. It covers practices such as cheating, copying and using another person’s work without appropriate acknowledgement. Incidents of academic misconduct may have serious consequences for students.

Plagiarism

UNSW regards plagiarism as a form of academic misconduct. UNSW has very strict rules regarding plagiarism. Plagiarism at UNSW is using the words or ideas of others and passing them off as your own. All Schools in the Business School have a Student Ethics Officer who will investigate incidents of plagiarism and may result in a student’s name being placed on the Plagiarism and Student Misconduct Registers.

Below are examples of plagiarism including self-plagiarism:

Copying: Using the same or very similar words to the original text or idea without acknowledging the source or using quotation marks. This includes copying materials, ideas or concepts from a book, article, report or other written document, presentation, composition, artwork, design, drawing, circuitry, computer program or software, website, internet, other electronic resource, or another person's assignment, without appropriate acknowledgement of authorship.

Inappropriate Paraphrasing: Changing a few words and phrases while mostly retaining the original structure and/or progression of ideas of the original, and information without acknowledgement. This also applies in presentations where someone paraphrases another’s ideas or words without credit and to piecing together quotes and paraphrases into a new whole, without appropriate referencing.

Collusion: Presenting work as independent work when it has been produced in whole or part in collusion with other people. Collusion includes:

Students providing their work to another student before the due date, or for the purpose of them plagiarising at any time
Paying another person to perform an academic task and passing it off as your own
Stealing or acquiring another person’s academic work and copying it
Offering to complete another person’s work or seeking payment for completing academic work

Collusion should not be confused with academic collaboration (i.e., shared contribution towards a group task).

Inappropriate Citation: Citing sources which have not been read, without acknowledging the 'secondary' source from which knowledge of them has been obtained.

Self-Plagiarism: ‘Self-plagiarism’ occurs where an author republishes their own previously written work and presents it as new findings without referencing the earlier work, either in its entirety or partially. Self-plagiarism is also referred to as 'recycling', 'duplication', or 'multiple submissions of research findings' without disclosure. In the student context, self-plagiarism includes re-using parts of, or all of, a body of work that has already been submitted for assessment without proper citation.

To see if you understand plagiarism, do this short quiz: https://student.unsw.edu.au/plagiarism-quiz

Cheating

The University also regards cheating as a form of academic misconduct. Cheating is knowingly submitting the work of others as their own and includes contract cheating (work produced by an external agent or third party that is submitted under the pretences of being a student’s original piece of work). Cheating is not acceptable at UNSW.

If you need to revise or clarify any terms associated with academic integrity you should explore the 'Working with Academic Integrity' self-paced lessons available at: https://student.unsw.edu.au/aim.

For UNSW policies, penalties, and information to help you avoid plagiarism see: https://student.unsw.edu.au/plagiarism as well as the guidelines in the online ELISE tutorials for all new UNSW students: http://subjectguides.library.unsw.edu.au/elise. For information on student conduct see: https://student.unsw.edu.au/conduct.

For information on how to acknowledge your sources and reference correctly, see: https://student.unsw.edu.au/referencing. If you are unsure what referencing style to use in this course, you should ask the lecturer in charge.

Student Responsibilities and Conduct

Students are expected to be familiar with and adhere to university policies in relation to class attendance and general conduct and behaviour, including maintaining a safe, respectful environment; and to understand their obligations in relation to workload, assessment and keeping informed.

Information and policies on these topics can be found on the 'Managing your Program' website.

Workload

It is expected that you will spend at least ten to twelve hours per week studying for a course except for Summer Term courses which have a minimum weekly workload of twenty to twenty four hours. This time should be made up of reading, research, working on exercises and problems, online activities and attending classes. In periods where you need to complete assignments or prepare for examinations, the workload may be greater. Over-commitment has been a cause of failure for many students. You should take the required workload into account when planning how to balance study with employment and other activities.

We strongly encourage you to connect with your Moodle course websites in the first week of semester. Local and international research indicates that students who engage early and often with their course website are more likely to pass their course.

View more information on expected workload

Attendance and Engagement

Your regular attendance and active engagement in all scheduled classes and online learning activities is expected in this course. Failure to attend / engage in assessment tasks that are integrated into learning activities (e.g. class discussion, presentations) will be reflected in the marks for these assessable activities. The Business School may refuse final assessment to those students who attend less than 80% of scheduled classes where attendance and participation is required as part of the learning process (e.g. tutorials, flipped classroom sessions, seminars, labs, etc.). If you are not able to regularly attend classes, you should consult the relevant Course Authority.

View more information on attendance

General Conduct and Behaviour

You are expected to conduct yourself with consideration and respect for the needs of your fellow students and teaching staff. Conduct which unduly disrupts or interferes with a class, such as ringing or talking on mobile phones, is not acceptable and students may be asked to leave the class.

View more information on student conduct

Health and Safety

UNSW Policy requires each person to work safely and responsibly, in order to avoid personal injury and to protect the safety of others.

View more information on Health and Safety

Keeping Informed

You should take note of all announcements made in lectures, tutorials or on the course web site. From time to time, the University will send important announcements to your university e-mail address without providing you with a paper copy. You will be deemed to have received this information. It is also your responsibility to keep the University informed of all changes to your contact details.

Student Support and Resources

The University and the Business School provide a wide range of support services and resources for students, including:

Business School Learning Support Tools
Business School provides support a wide range of free resources and services to help students in-class and out-of-class, as well as online. These include:

Academic Communication Essentials – A range of academic communication workshops, modules and resources to assist you in developing your academic communication skills.
Learning consultations – Meet learning consultants who have expertise in business studies, literacy, numeracy and statistics, writing, referencing, and researching at university level.
PASS classes – Study sessions facilitated by students who have previously and successfully completed the course.
Educational Resource Access Scheme – To support the inclusion and success of students from equity groups enrolled at UNSW Sydney in first year undergraduate Business programs.

The Nucleus - Business School Student Services team
The Nucleus Student Services team provides advice and direction on all aspects of enrolment and graduation. Level 2, Main Library, Kensington 02 8936 7005 / https://nucleus.unsw.edu.au/en/contact-us

Business School Equity, Diversity and Inclusion
The Business School Equity, Diversity and Inclusion Committee strives to ensure that every student is empowered to have equal access to education. The Business School provides a vibrant, safe, and equitable environment for education, research, and engagement that embraces diversity and treats all people with dignity and respect. BUSEDI@unsw.edu.au

UNSW Academic Skills
Resources and support – including workshops, individual consultations and a range of online resources – to help you develop and refine your academic skills. See their website for details.
academicskills@unsw.edu.au

Student Support Advisors
Student Support Advisors work with all students to promote the development of skills needed to succeed at university, whilst also providing personal support throughout the process.
John Goodsell Building, Ground Floor.
advisors@unsw.edu.au
02 9385 4734

International Student Support
The International Student Experience Unit (ISEU) is the first point of contact for international students. ISEU staff are always here to help with personalised advice and information about all aspects of university life and life in Australia.
Advisors can support you with your student visa, health and wellbeing, making friends, accommodation and academic performance.
International.student@unsw.edu.au
02 9385 4734

Equitable Learning Services
Equitable Learning Services (formerly Disability Support Services) is a free and confidential service that provides practical support to ensure that your health condition doesn't adversely affect your studies. Register with the service to receive educational adjustments.
Ground Floor, John Goodsell Building.
els@unsw.edu.au
02 9385 4734

UNSW Counselling and Psychological Services
Provides support and services if you need help with your personal life, getting your academic life back on track or just want to know how to stay safe, including free, confidential counselling.
Level 2, East Wing, Quadrangle Building.
counselling@unsw.edu.au
02 9385 5418

Library services and facilities for students
The UNSW Library offers a range of collections, services and facilities both on-campus and online.
Main Library, F21.
02 9065 9444

Moodle eLearning Support
Moodle is the University’s learning management system. You should ensure that you log into Moodle regularly.
externalteltsupport@unsw.edu.au
02 9385 3331

UNSW IT
UNSW IT provides support and services for students such as password access, email services, wireless services and technical support.
UNSW Library Annexe (Ground floor).
02 9385 1333

Support for Studying Online

The Business School and UNSW provide a wide range of tools, support and advice to help students achieve their online learning goals.

The UNSW Guide to Online Study page provides guidance for students on how to make the most of online study.

We recognise that completing quizzes and exams online can be challenging for a number of reasons, including the possibility of technical glitches or lack of reliable internet. We recommend you review the Online Exam Preparation Checklist of things to prepare when sitting an online exam.

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1. Course Details

Summary of Course

Teaching Times and Locations

Course Policies & Support

Course Aims and Relationship to Other Courses

Student Learning Outcomes

2. Staff Contact Details

Communication with staff

3. Learning and Teaching Activities

Approach to Learning and Teaching in the Course

How to Use These Study Materials

Features of the Study Guide

Audio Conferences

Learning Activities and Teaching Strategies

4. Assessment

Formal Requirements

Assessment Structure

Assessment Summary

On-line quizzes

Take Home Exam

Assessment Format

Assignment cover sheets

Abstract

Margins

Headings/Table of contents

Style of presentation

Footnotes and citation system

Bibliography

Assignment Submission Procedure

Assignment submissions and deadlines

Due date and time

Name and save your assignment documents

Problems with Moodle assignment submission

Assignment return

Assessment Feedback

Special Consideration

Late Submission and Penalties

General points

The following is very important:

Protocol for Viewing Final Exam Scripts

Quality Assurance

5. Course Resources

Prescribed text:

Citation and Style Guide:

Recommended References:

Electronic Databases:

6. Course Evaluation & Development

7. Course Schedule

8. Policies and Support

UNSW Graduate Capabilities

Plagiarism

Cheating

Workload

Attendance and Engagement

General Conduct and Behaviour

Health and Safety

Keeping Informed

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