3 ECTS credits
75 h study time

Offer 1 with catalog number 8020306GNR for all students in the 2nd semester at a (G) Postgraduate - preliminary level.

2nd semester
Enrollment based on exam contract
Grading method
Grading (scale from 0 to 20)
Can retake in second session
Taught in
Faculty of Law and Criminology
Economic Law
Educational team
Lieven Denys (course titular)
Activities and contact hours
21 contact hours Lecture
Course Content



  1. Basic principles and sources of international tax law: problems & solutions


  • tax sovereignty, territoriality, double & multiple taxation; international tax avoidance & evasion
  • international tax  competences &  policy (G-20, OECD, EU, bilateral, regional and state level)
  • Legal solutions:
    • UN and OECD (Model) for bilateral tax treaties to avoid double taxation (balanced allocation of  taxing rights)
    • EU tax harmonisation: Directives in corporate taxation (positive integration) 
    • EU case law: predominance of single market principles on corporate taxation (free movement of capital, freedom of business establishment; negative integration)
    • International Agreements on cooperation between tax authorities; EU Directives; US-FATCA regulations; (transparency and reporting standards)
    • EU State-aid policing
  • Negotiated solutions:
    • Advanced pricing Agreements (rulings) with businesses
    • Executive Agreements amongst authorities
    • Procedure Amiable amongst authorities
    • Transfer pricing Arbitration
  • International Tax Policy: harmful tax competition; Base erosion and profit shifting (BEPS) and Common Reporting Standard (CRS) for international tax transparency
  • Leading comparative publication on (summary) corporate tax systems (e.g. IBFD)
  • OECD: authoritative documents & report.


  1. Perspective of International Business Enterprises: Tax Planning Issues (optimisation & protection)


  • Delocalisation: state-competition on tax incentives
  • Going global: tax structuring foreign investment (home tax treatment foreign taxed profit & losses)
  • International mergers & acquisitions
  • Intra-group profit shifting & transfer pricing: dealing at arm length; base erosion; advanced rulings; arbitration procedures
  • General Tax Abuse concepts ; measures to counteract tax avoidance
  • Specific measures: Use of Tax haven: Controlled Foreign Corporation legislation ( look-through); hybrid financing; thin capitalisation
  • Inward investment: localisation of EU headquarters & EU bridge-heads: holding company, finance company, royalty company (intellectual property); expat incentives
  • International Corporate Social Responsibility in tax matters; international tax leaks (Offshore – Lux – Swiss – Panama etc) and protection of business secrets and confidentiality; guidelines & soft law
  • Data-protection, due process & fair tax administration


  1. Perspective of tax diplomacy (joined & common state & business interests):


  • EU Forbidden State aid &  EU Com approval; EU Communications; Harmful tax competition (reports and committees)
  • Negotiation of tax treaties; input business enterprises (federations)
  • Negotiation of (executive) tax arrangements
  • International Advanced Pricing Arrangements
  • Procedure amiable; interpretive agreements; settlement of disputes; arbitration.     
  • International administrative  tax cooperation (requests for tax information & investigation; exchange of data;  bank secrecy & (EU)FATCA; tax collection, enforcement)
  • International judicial cooperation in tax matters;
  • Tax & Diplomacy: assist outward investment (incentive abroad); attract  inward investment; international tax competition
  • Lobbying on international tax matters
Course material
Digital course material (Required) : Corporate International Taxation for Diplomacy and International Business
Additional info


Study material


  • models & reports (available on the internet; links communicated)
  • handbooks on International and European Tax Law


Complementary study material


cfr. classes

Learning Outcomes

General competences

Learning objectives


The course aims to introduce and prepare students and participants to operate in the (legal) international tax environment of business enterprises and diplomacy serving  economic relations.


Participants will develop their understanding of the phenomena of international double   and multiple taxation, tax avoidance and evasion and tax competition among states   resulting from territorial tax sovereignty and the modest achievements of tax policy and harmonisation in a globalising economy.


Participants will familiarize with the international instruments and mechanisms to cope with these problems and challenges, to protect the business interests and investment, to optimise tax positions, to safeguard the taxing rights of the states and implement their tax policies including their legitimate tax incentives and securing fair play in international taxation by developing the skills to prevent and resolve international tax disputes.

Core to the discussions in the course will be the OECD Model Convention, that inspired the more than 3000 Tax Treaties around the world ,  and  the OECD initiatives   the “ Common Reporting Standard”  (CRS) for  tax transparency and the  “Base erosion and profit shifting Action Plan” ( BEPS) endorsed by the G-20,   that are  currently been rolled out at high  speed.         


The final grade is composed based on the following categories:
Oral Exam determines 100% of the final mark.

Within the Oral Exam category, the following assignments need to be completed:

  • Oral exam with a relative weight of 1 which comprises 100% of the final mark.

Additional info regarding evaluation


Allowed unsatisfactory mark
The supplementary Teaching and Examination Regulations of your faculty stipulate whether an allowed unsatisfactory mark for this programme unit is permitted.

Academic context

This offer is part of the following study plans:
Postgraduate Certificate Economic Diplomacy: Standaard traject
Postgraduate Certificate International Trade and Investment: Standaard traject
Postgraduate Certificate Flagship Programme in Economic Diplomacy and International Business: Standaard traject