TAX 661 (TAX 6610): Case Studies in International Tax Planning

Contents
The course provides an in-depth overview of international tax planning and structuring, including the use of financing companies in both outbound and inbound investment scenarios. It introduces common tax planning strategies using intellectual property, such as the “Double Irish with a Dutch Sandwich,” the design of cross-border financing structures, and the strategic use of double taxation treaties. In addition, the course examines the implications of the German interest limitation rule (“Zinsschranke”) and comparable foreign anti-tax avoidance provisions. The tax planning structures taught in this course build on the foundations established in other courses and extend them by addressing more advanced, complex cross-border scenarios.

Learning outcomes
The students learn how to apply their skills in basic taxation on practical cases. The students get a deeper insight into the basics of the most important areas in international tax planning and tax structuring. The students learn how to implement their theoretical knowledge into practical scenarios. Thereby special attention is paid to the application of the wording of law – especially using inaccuracies in law. The students learn to develop international tax planning and tax structuring ideas across different types of taxes.

Necessary prerequisites
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Recommended prerequisites
Knowledge of contents of Module TAX 630

Examiner Performing lecturer

Prof. Dr. Christoph Spengel Prof. Dr. Michael Schaden