TAX 630: International Business Taxation


  • Basics of international business taxation
  • Taxation of inbound investments
  • Taxation of outbound investments
  • Transfer pricing
  • Cross-border reorganisations

Learning outcomes
Students know the basics of international taxation (national tax law, double taxation conventions, primary and secondary EU law) and the causes of double taxation. Students understand the tax consequences of establishing domestic and foreign permanent establishments as well as domestic and foreign corporations. Students understand the impact of transfer pricing on the companies’ tax burden. Most notably, students are able to evaluate how multinational companies make use of internationally diverging tax burdens.

Necessary prerequisites

Recommended prerequisites
Knowledge of contents of Module TAX 520 or Module TAX 530

Forms of teaching and learningContact hoursIndependent study time
Lecture2 SWS8 SWS
Exercise class2 SWS5 SWS
ECTS credits6
Graded yes
Form of assessmentWritten exam (90 min, 70%), individual assignment and group presentation (30%)
Restricted admissionno
Further information
Performing lecturer
Prof. Dr. Christoph Spengel
Prof. Dr. Christoph Spengel
Frequency of offeringSpring semester
Duration of module 1 semester
Range of applicationM.Sc. MMM, M.Sc. Bus. Edu., M.Sc. Econ., M.Sc. Bus. Inf., LL.M., MAKUWI
Preliminary course work
Program-specific Competency GoalsCG 1, CG 2
LiteratureEndres, D./Spengel, C. (Ed.): International Company Taxation and Tax Planning, Alphen aan den Rijn 2015, pp. 189–388.
Course outlineInternational Taxation and Managerial Decisions
Overview on Tax Systems – an International Comparison
Impact of Taxation on Managerial Decisions
Relevant Tax Drivers for International Location Decisions
Fundamentals of International Taxation
Liability to Tax and International Double Taxation
Avoidance of International Double Taxation on Income: Different Approaches and Consequences
Avoidance of International Double Taxation on Income: The Role of Bilateral Tax Treaties
Double Non-Taxation
Property Tax and Inheritance and Gift Tax
Taxation of Cross-border Investments
Systematization of Cross-border Investments
Direct Business
Permanent Establishment / Business Profits
Allocation of Profits
Direct Business
Permanent Establishment / Business Profits
Proposals for Reforming Business Taxation within the EU