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DESCRIPTION Each year, LL.M. students may take a total of 9 ECTS from the courses taught in English within the framework of the MLaw International Tax.
Participants following this course will learn the following topics relevant to taxation of MNEs from an international and comparative tax policy perspective: types of formulary apportionment (multi factor or single factor), application of the arm's length principle, functional analysis, value chain, value network & value shop analysis, transfer pricing methods and comparability analysis, special consideration for intangibles, services & financing (through loans, guarantees, cash pooling and captive insurance), the use of cost contribution arrangements, business restructurings and supply chain management (principal structures), taxation of business activities (permanent establishments and related attribution requirements), state aid & transfer pricing rules, dispute prevention and resolution avenues, reduction of effective corporate tax rates and the future of the arm's length principle in the post BEPS and Digitalized world.
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PROFESSOR
CREDITS
6 ECTS credits
