Not currently offered
Course code



10 units


6000 level

Course handbook


International Taxation has become increasingly important given Australia's growing presence in the globalized economy. Non-residents are increasingly doing business with Australian residents, and vice-versa. This course will provide students with advanced and specialized knowledge of the key Australian taxation rules that affect international business and investment transactions. The course examines relevant policy issues in international taxation, as well as the relevant provisions in legislation, case law, and Australian Taxation Office rulings. The course considers Australia's jurisdiction to tax based on residence and source, Australian rules for the taxation of a resident's foreign income (relief from double taxation, accruals taxation of foreign income and applicable exemptions), Australian rules for the taxation of a non-resident's Australian source income (business income, interest, dividends and royalties), introduction to tax treaties, transfer pricing and thin capitalization.


Not currently offered.

Learning outcomes

On successful completion of the course students will be able to:

1. Demonstrate advanced understanding and knowledge of the principles of law in Australia applicable to the taxation of international business and investment transactions;

2. Demonstrate advanced knowledge of the policies underlying Australia¿s rules for taxing international business and investment transactions.

3. Apply specialised knowledge of Australia¿s international taxation rules to international business and investment transactions.

4. Analyse and evaluate key policy debates surrounding future development of the Australia¿s international taxation rules.


The topics in this course include the following:

  1. Introduction to international taxation, including policy considerations.
  2. Residence and Source rules.
  3. Residents and foreign source income.
  4. Foreign residents and Australian-sourced income.
  5. Double taxation agreements.
  6. Transfer pricing.
  7. Thin capitalisation.


This course is only available to students enrolled in the Masters of Laws program.

Assumed knowledge

It is recommended that students who do not have detailed knowledge of the Australian income tax system consider completing Advanced Taxation Law before enrolling in this course. Students may also contact the Program Convenor to discuss their enrolment.

Assessment items

Essay: Research Essay

Case Study / Problem Based Learning: Problem based written assignment