The course provides enhanced explication of legal and extra-legal issues arising in international taxation of income. It focuses on international legal double taxation, its causes and effects, as well as the tools and instruments for the elimination or at least moderation of the same, including, above all, the instruments contained in international double taxation treaties (DTTs). Students will become acquainted with basic notions, terminology, and sources of international tax law. They will work with the texts of model treaties on elimination of double taxation as well as selected bilateral treaties actually concluded and applied between individual countries. They will learn to find, interpret, and apply relevant rules of elimination of international double taxation and will be given the opportunity of learning how to resolve selected practical cross-border taxation situations by application of gained skills and knowledge.
The course is not strongly based on positive law of the Czech Republic or any particular country, and the competences gained in it by the students can thus be utilized in any jurisdiction in which they may operate in the future.
Last update: Šicnerová Barbora, Mgr. (13.05.2025)
The course provides enhanced explication of legal and extra-legal issues arising in international taxation of income. It focuses on international legal double taxation, its causes and effects, as well as the tools and instruments for the elimination or at least moderation of the same, including, above all, the instruments contained in international double taxation treaties (DTTs). Students will become acquainted with basic notions, terminology, and sources of international tax law. They will work with the texts of model treaties on elimination of double taxation as well as selected bilateral treaties actually concluded and applied between individual countries. They will learn to find, interpret, and apply relevant rules of elimination of international double taxation and will be given the opportunity of learning how to resolve selected practical cross-border taxation situations by application of gained skills and knowledge.
The course is not strongly based on positive law of the Czech Republic or any particular country, and the competences gained in it by the students can thus be utilized in any jurisdiction in which they may operate in the future.
Last update: Šicnerová Barbora, Mgr. (13.05.2025)
Requirements to the exam -
Examination will consist of a written test (single best answer choice of provided alternatives). During the test, students will be allowed to use provided resources including texts of selected DTTs. The test will comprise 18 questions, some of them structured in the form of a practical cross-border taxation situation. For each correct answer the student will get 1-3 points depending on the complexity of the question. The maximum number of achievable points will be 30. Successful passing the exam will require achieving at least 18 points.
Last update: Šicnerová Barbora, Mgr. (13.05.2025)
Examination will consist of a written test (single best answer choice of provided alternatives). During the test, students will be allowed to use provided resources including texts of selected DTTs. The test will comprise 18 questions, some of them structured in the form of a practical cross-border taxation situation. For each correct answer the student will get 1-3 points depending on the complexity of the question. The maximum number of achievable points will be 30. Successful passing the exam will require achieving at least 18 points.
Last update: Šicnerová Barbora, Mgr. (13.05.2025)
Syllabus -
The subject covers following topics:
· Introduction in international taxation
· Causes and cures of double taxation
· History and notion of tax treaties
· DTT scope and definitions
· Tax residents
· Permanent establishment
· Allocation of taxation rights
· Methods of elimination of double taxation
· Non-discrimination
· Mutual agreement procedures
· Limitation of benefits
· Multilateral instrument (MLI)
· Exchange of information
· International administrative assistance in tax matters
· Wrap-up and practical exercises
Last update: Šicnerová Barbora, Mgr. (28.08.2025)
The subject covers following topics:
· Introduction in international taxation
· Causes and cures of double taxation
· History and notion of tax treaties
· DTT scope and definitions
· Tax residents
· Permanent establishment
· Allocation of taxation rights
· Methods of elimination of double taxation
· Non-discrimination
· Mutual agreement procedures
· Limitation of benefits
· Multilateral instrument (MLI)
· Exchange of information
· International administrative assistance in tax matters
· Wrap-up and practical exercises
Last update: Šicnerová Barbora, Mgr. (28.08.2025)
Learning resources -
Basic literature:
Presentation outlines for individual lectures OECD (2019), Model Tax Convention on Income and on Capital 2017 (Full Version), OECD Publishing. http://dx.doi.org/10.1787/g2g972ee-en. ISBN 978-92-64-30378-2 (print), ISBN 978-92-64-30699-8 (PDF) UNITED NATIONS, Model Double Taxation Convention between Developed and Developing Countries 2021. United Nations, New York, 2021. ISBN: 9789212591841, eISBN: 9789210001007 Particular Bilateral Conventions on Elimination of Double Taxation will be distributed electronically during the course
Other literature:
OECD Commentaries on the Articles of the Model Tax Convention Vienna Convention on the Law of Treaties 1969 LANG, Michael, Introduction to the Law of Double Taxation Conventions 3rd edition. Linde Verlag Ges.m.b.H., Wien 2021. ISBN: 978-90-8722-684-8 (print/online), 978-90-8722-685-5 (ePub), 978-90-8722-686-2 (PDF).
Last update: Šicnerová Barbora, Mgr. (29.08.2025)
Basic literature:
Presentation outlines for individual lectures OECD (2019), Model Tax Convention on Income and on Capital 2017 (Full Version), OECD Publishing. http://dx.doi.org/10.1787/g2g972ee-en. ISBN 978-92-64-30378-2 (print), ISBN 978-92-64-30699-8 (PDF) UNITED NATIONS, Model Double Taxation Convention between Developed and Developing Countries 2021. United Nations, New York, 2021. ISBN: 9789212591841, eISBN: 9789210001007 Particular Bilateral Conventions on Elimination of Double Taxation will be distributed electronically during the course
Other literature:
OECD Commentaries on the Articles of the Model Tax Convention Vienna Convention on the Law of Treaties 1969 LANG, Michael, Introduction to the Law of Double Taxation Conventions 3rd edition. Linde Verlag Ges.m.b.H., Wien 2021. ISBN: 978-90-8722-684-8 (print/online), 978-90-8722-685-5 (ePub), 978-90-8722-686-2 (PDF).
Last update: Šicnerová Barbora, Mgr. (29.08.2025)
Entry requirements - Czech
Students are recommended to have passed a general course of Public International Law at any university.
