TABL5583 International Business Taxation - 2020

Subject Code
Study Level
Commencing Term
Term 2
Total Units of Credit (UOC)
Delivery Mode
On Campus
Taxation & Business Law
The course outline is not available for current term. To view outlines from other year and/or terms visit the archives

1. Course Details

Summary of Course

In the world economy barriers to international direct investment are rapidly falling. Of the remaining barriers some of the most significant are differences in legal and tax systems and inadequate co-ordination of different tax systems. In recent years, concerns about multinational companies avoiding taxation through the use of the international tax system has led to increased scrutiny of international transactions.

This course discusses principles relevant to international taxation and uses Australian international tax rules to highlight international tax issues and policy choices. Special emphasis is given to practical tax issues associated with international direct investments.

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

Course Aims and Relationship to Other Courses

This course aims to:

  1. Provide students with an overview of principles of Australian international taxation
  2. Develop students’ ability to research issues relating to Australian international taxation
  3. Illustrate some of the considerations relevant to international tax planning
  4. Challenge students to think of alternative approaches to structuring international transactions
  5. Challenge students to think critically about the design of Australian international business taxation rules

2. Staff Contact Details

Position Title Name Email Location Phone Consultation Times
Lecturer-in-chargeProfJohn TaylorRoom 2060, Level 2, Quadrangle building – Ref E15+61 2 9385 3292By appointment
LecturerAProfYan XuRoom 2070, Level 2, Quadrangle Business School - Ref E15+61 2 9385 3259 By appointment

​When you contact staff by email, please:

  • Use your University (not personal) email address
  • Specify the course TABL5583 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

​The philosophy of learning and teaching underpinning this course is one of problem based learning. Students will be encouraged to apply international tax law principles in the context of case studies, simulation games and a tax planning assignment. The aim is to promote deep learning by examining alternative approaches to achieving outcomes in particular fact situations. Students will be encouraged to read widely and think critically about Australia’s approaches to the design of its international tax law.

Learning Activities and Teaching Strategies

The course will be conducted by weekly 3 Webinars. One focus of the course is on principles applicable to the income taxation of international transactions. Emphasis will be placed on taxation principles relevant to international direct investment. At relevant points a comparison will be made with the legislation of other jurisdictions as other possible responses to these issues. Another focus of the course is on international tax planning. Here the course examines general principles and objectives of international tax planning. Students are then required to apply these general principles to hypothetical fact situations involving Australia and other specific jurisdictions.

The classes will be a blend of lecturer presentations and lecturer-led discussions of case studies (case studies that will be discussed in class to illustrate the relevant concepts). Extensive written course materials will be placed on Moodle at the beginning of the term. Students will be required to read the relevant materials on Moodle before the class in which those materials are discussed. The materials on Moodle will often contain problems and discussion questions. Students are required to attempt the problems and discussion questions before the class in which those materials are discussed. Students should be prepared to respond to lecturer questions concerning the case studies that have been allocated to them for the particular class.

Students will develop an understanding of general principles of international tax planning through participation in the on-line game/simulation called Playtax: Adventures in International Tax Planning. The game will be demonstrated and used in class throughout the term. Students are also encouraged to use this game during their own private study to assist in the preparation of their international tax planning assignment.

On-line quizzes will be placed on Moodle during Week 6 (flexibility week). Although students are not required to attempt the on-line quizzes they are encouraged to do so as a formative learning exercise. A Discussion Forum will be open on Moodle during Week 6 to provide students with the opportunity to compare their experiences in using Playtax: Adventures In International Tax Planning and to float ideas for their international tax planning assignment. Additional pre-recorded content may be placed on Moodle in Week 6 providing real world examples of issues discussed in Week 5 and/or relevant to the international tax planning assignment.

To develop students awareness of current issues and policy issues in International Taxation students will be required to write a research paper on a topic chosen in consultation with the Lecturer in Charge. Links to relevant literature and on-line presentations will be placed on Moodle throughout the Term.

5. Course Resources

The website for this course is on Moodle.

The “textbook” for this course is:

  • TABL5583 Course Materials (available via Moodle). If students choose, they are able to print these materials at their own expense.

Students should also have access to either:

  • Taylor, Walpole, Burton, Ciro and Murray, Understanding Taxation Law 2020, Lexis Nexis or
  • Woellner, Barkoczy, Murphy, Evans and Pinto, Australian Taxation Law, latest Edition, CCH

Online resources

  • Students will be required to access the relevant taxation legislation throughout the term. This can be accessed via the CCH database (via the UNSW library), or via the Thomson Reuters Checkpoint database or via Austlii.
  • Students will also need to refer to the Australian Treasury Website which contains a list of Australian Income Tax Treaties with hypertext links to texts of each treaty.
  • The IBFD database (available through the UNSW library) provides an invaluable source of data in relation to overseas tax jurisdictions, and will be demonstrated in the first class.
  • Additional readings for the course will be provided 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.

Each year feedback is sought from students and other stakeholders about the courses offered in the School and continual improvements are made based on this feedback. UNSW's myExperience survey is one of the ways in which student evaluative feedback is gathered. In this course, we will seek your feedback through the end of term myExperience responses.

Feedback from previous students indicated:

  • Lack of a specific textbook makes studying the course difficult;
  • Use of ‘simulation games’ as a form of assessment took up too much class time and did not help in developing an understanding of key concepts;
  • Students were unsure of the requirements of the tax planning assignment.

As a result of this feedback:

  • Extensive online materials have been developed for the course and will be available on Moodle before the beginning of the term;
  • Simulation games have been removed as part of the course;
  • Students will be required to submit a synopsis/plan of their tax planning assignment in Week 4, so early feedback can be provided.
  • Case studies will be allocated to individual students so that additional feedback can be provided to them

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:
Week Activity Topic Assessment/Other
Week 1: 1 JuneSeminar


General framework of Australian international tax rules – principles of international tax planning – Demonstration of PlayTax – outline of Tax Treaties.

On-line recorded lecture on Residence

  • Allocation of case studies to students confirmed
Week 2: 8 JuneSeminar

Residence – case study discussion corporate residence

Source rules – lecture mode – business profits

Week 3: 15 JuneSeminar

Source rules – case study discussion source of business profits

Taxation of foreign source income of residents – lecture mode – foreign income tax offsets – exemptions – interaction with dividend imputation

Week 4: 22 JuneSeminar

Taxation of foreign source income – case study on foreign income tax offsets

Taxation of foreign source income of residents – lecture mode – CFCs

 Synopsis due for tax planning assignment

Week 5: 29 JuneSeminar

Taxation of foreign source income – case study on interaction of CFCs, Exemptions, Foreign Income Tax Offsets and Dividend Imputation

Taxation of non-residents – withholding taxes – capital gains – lecture mode

Week 6: 6 JulySeminar

Optional on-line quizzes on content in Weeks 1 to 5

Discussion Forum Debrief on Playtax and exchange of ideas on Tax Planning assignment

Links to recorded lectures on topical issues and tax planning


Week 7: 13 JulySeminar

Taxation of non-residents – case study on capital gains

Anti-avoidance provisions – lecture mode – thin cap

Critical reflection on Playtax due Week 7

Week 8: 20 JulySeminar

Anti-avoidance provisions – case study – thin cap

Anti-avoidance provisions – lecture mode – transfer pricing

Week 9: 27 JulySeminar

Anti-avoidance provisions – case study – transfer pricing

Tax Treaties– lecture mode

Week 10: 3 AugustSeminar

Tax Treaties – case study

Anti-avoidance provisions – Part IVA, MAAL, DPT, Hyrbid Mismatches – lecture mode

On-line discussion forum for general debrief on Playtax

Tax planning assignment due Week 10

Research paper due in UNSW exam period

8. Policies and Support

Information about UNSW Business School protocols, University policies, student responsibilities and education quality and support.

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.  Separate PLOs for honours and postgraduate research programs are included under 'Related Documents'.

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 CapabilitiesBusiness 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 Centre.

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.


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:


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:

For UNSW policies, penalties, and information to help you avoid plagiarism see: as well as the guidelines in the online ELISE tutorials for all new UNSW students: For information on student conduct see:

For information on how to acknowledge your sources and reference correctly, see: 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.


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


Your regular and punctual attendance at lectures and seminars or in online learning activities is expected in this course. The Business School reserves the right to 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.).

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 EQS Consultation Program
The Consultation Program offers academic writing, literacy and numeracy consultations, study skills, exam preparation for Business students. Services include workshops, online resources, individual and group consultations. 
Level 1, Room 1035, Quadrangle Building.
02 9385 4508

Communication Resources
The Business School Communication and Academic Support programs provide online modules, communication workshops and additional online resources to assist you in developing your academic writing.

Business School Student Centre
The Business School Student Centre provides advice and direction on all aspects of admission, enrolment and graduation.
Level 1, Room 1028 in the Quadrangle Building
02 9385 3189

UNSW Learning & Careers Hub
The UNSW Learning & Careers Hub provides academic skills and careers support services—including workshops, individual consultations and a range of online resources—for all UNSW students. See their website for details.
Lower Ground Floor, North Wing Chancellery Building.
02 9385 2060

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.
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.
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.
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.
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 9385 2650

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

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