International Taxation and Accounting

Learning Outcome 1: Explain and discuss the reasons why accounting and taxation are constantly evolving and developing and why different societies and stakeholders have varying benchmarks for the appropriateness of accounting standards and taxation policy.

Learning Outcome 2: Make judgments on, explain, reflect on double taxation, transfer pricing and anti-avoidance issues and critically appraise and consider the appropriateness of international tax planning on business and society.

Learning Outcome 3: Critically assess, analyse, evaluate, reflect on the role and contributions of supranational organisations like the IMF, the OECD, the UN on a nation's tax policy and culture, tax harmonisation and tax competition.

Learning Outcome 4: Resolve tax issues using information from all areas of the module content along with information from all their learning and teaching activities and information from the public domain on current issues in taxation.

Topic 1: MNCs, Global Accounting and Taxation Diversity

Topic 2: Double Taxation Treaties

Topic 3: International Tax Planning

Topic 1: MNCs, Global Accounting and Taxation Diversity

Multinational companies (MNCs) are characterised as engines of global economic development, technological transfer and deepening globalisation (Evans et al., 2017). Given that MNCs' operations spread across several countries, their international involvement is evident in different forms, bringing the need for reforms in accounting and tax systems due to each country's culture. However, diversity in accounting and tax practices across countries generate problems for a number of different groups including MNCs.

Required:
There will be a research seminar for International Taxation and Accounting students for which you are asked to prepare a paper on MNCs. The theme of the seminar is the role of MNCs and their contributions to the World Economy.

Imagine that you are an international taxation and accounting researcher and that you are asked to prepare at the seminar on theme:
"MNCs are engines of global economic development, technological transfer and deepening globalisation."

Your paper should critically assess the concepts of ‘multinational companies', ‘international involvement' and ‘global economic development'. Your paper should also critically evaluate, discuss and analyse the significance of MNCs, the reasons for their international involvement and the extent to which they contribute to global economic development.

Your paper should also include your own judgments of the challenges posed by accounting and taxation diversity on MNCs' practices and global expansion. Your discussions and arguments must be supported by relevant examples and should be grounded in the current academic debates on MNCs.

Topic 2: Double Taxation Treaties

Double tax treaties are usually agreements between two states (the contracting states). No two states have exactly the same tax system. They have different definitions of what constitutes tax residence, different interpretations of the source principle and possibly different systems of double tax relief. Double tax treaties are needed to provide a consistent, common and logical basis by which contracting states can share between themselves the tax rights over persons and institutions that have a connection with both states (Oats, 2021).
Required:
Imagine that you are employed with Price Sea Castle as the Double Taxation lead, an international consultancy firm with offices in Europe, Africa and the Americas. Trainee consultants from these various country offices will be attending an online seminar on ‘Double Taxation - Paying your fair share of tax'. You are tasked to prepare a paper for circulation prior to the seminar for the trainee consultants who have limited knowledge on Double Taxation issues.
The paper requires you to critically assess the concept of ‘Bilateral Double Taxation Treaties.' Your assessment should include a critical evaluation of the objectives of Double Taxation Treaties; analysis of Double Taxation Treaties, Double Taxation Treaties in relation to the domestic law of a jurisdiction, and why Double Taxation Treaties may be ‘bad' for Developing Countries. Your critique should also include your own judgments on the contributions of supranational organisations like the OECD and the UN to the debates on Double Taxation Treaty issues.

Topic 3

Imagine that you are a consultant with the International Centre for Tax and Development which primarily provides advice on International Tax Planning matters to tax professionals and investors. You notice that concerns are increasingly raised with you about tax havens, base erosion of profits, the Digital Economy, tax competition, MNCs making more profits but paying less taxes, MNCs moving to low tax regimes etc. You are invited to give a presentation and lead discussions in a forum for Tax Administrators from European, Pan-African and Latin American countries.

Required:

Prepare a discussion paper to address the issues raised. Your discussion paper should include but not limited to the following issues:

1. Critical assessment of the report by Shaxson (2019), Tackling tax havens. Finance and Development, IMF.
2. Critical discussions of the current debates on tax havens.
3. Critical assessment of at least two global initiatives that States/countries have engaged or adopted to both increase transparency and minimise the occurrence of tax avoidance.