Comparative International Tax Systems

Tax and Revenue Management October 25, 2025
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Introduction

This course offers a detailed, comparative analysis of the diverse tax regimes employed by major economies and emerging markets across the globe. We move beyond a single jurisdiction’s laws to explore the structural differences in income, consumption, and corporate taxation. The course examines how different countries address common challenges like tax competition, digitalization of the economy, and cross-border transactions. Participants will gain a broad, international perspective, enabling them to understand the rationales behind divergent policy choices and assess their effectiveness in a global context.

Objectives

Upon completion of this course, participants will be able to:

  • Compare and contrast the tax structures of at least four major global economies (e.g., US, EU, China, BRICS).
  • Analyze the economic and policy rationales for adopting different tax bases (e.g., global vs. territorial taxation).
  • Evaluate the impact of tax competition and tax harmonization efforts across regions.
  • Identify key features and mechanisms of regional tax arrangements (e.g., EU VAT system).
  • Understand the complexities of taxing multinational enterprises (MNEs) under different systems.
  • Critically assess the implications of the OECD’s Base Erosion and Profit Shifting (BEPS) project.
  • Explain the administration and compliance burdens imposed by different global systems.
  • Propose informed policy adjustments based on international best practices.

Target Audience

  • International Tax Managers and Consultants
  • Government Officials involved in Tax Treaty Negotiations
  • Policy Analysts focused on Global Fiscal Issues
  • Academics and Researchers in International Law/Economics
  • Professionals in Multinational Corporations (MNCs)
  • Tax Lawyers specializing in Cross-Border Transactions
  • Trade and Investment Promotion Officials

Methodology

  • Country-specific comparative analysis presentations (Group activity)
  • Scenario-based exercises on applying transfer pricing methods
  • Discussions on the political economy of BEPS implementation
  • Guest speakers from international tax bodies
  • Policy debate on the merits of a global minimum tax
  • Simulated treaty negotiation exercise

Personal Impact

  • Comprehensive, globally-informed perspective on tax policy and law.
  • Expertise in international tax concepts crucial for MNC operations.
  • Improved ability to advise on cross-border transactions and structures.
  • Capacity to anticipate global regulatory changes (e.g., BEPS implementation).
  • Enhanced professional credibility in the international finance community.

Organizational Impact

  • Better-designed domestic tax laws benchmarked against international best practices.
  • Increased effectiveness in negotiating and interpreting tax treaties.
  • Reduced risk of international tax disputes and costly litigation.
  • Improved ability to combat cross-border tax evasion and avoidance schemes.
  • Strategic advantage in attracting foreign direct investment (FDI) through competitive design.

Course Outline

Unit 1: Structural Foundations of Global Systems

Taxation Models: Territorial vs. Worldwide
  • Defining the scope of tax jurisdiction (residence and source principles)
  • Exemption method vs. credit method for avoiding double taxation
  • Policy justifications for territorial and worldwide systems
  • Hybrid systems and their complexity
  • Recent trends in moving toward territoriality
Comparative Analysis of Tax Bases
  • Corporate Tax systems: Rate structures, depreciation rules, and loss carryovers
  • Personal Income Tax: Progressive vs. flat rates, treatment of capital income
  • Consumption Tax: VAT vs. Sales Tax—design and administration differences
  • Wealth and Property Taxes in different national contexts

Unit 2: Regional and Country-Specific Systems

European Union Tax Environment
  • Directives and Regulations on Corporate Tax (e.g., ATAD)
  • The harmonized VAT system in the EU
  • State aid rules and their impact on national tax incentives
  • The role of the European Court of Justice (ECJ) in tax matters
Case Studies in Global Tax Systems
  • The US Tax System: Features of the TCJA and subpart F
  • Emerging Economies (e.g., Brazil, India, China): Unique structural features
  • Small Economies and Tax Havens: Role and policy responses

Unit 3: International Corporate Tax Issues

Transfer Pricing and Profit Allocation
  • The Arm’s Length Principle (ALP) and its challenges
  • OECD Transfer Pricing Guidelines and local regulations
  • Methods for determining arm’s length prices (e.g., CUP, Resale Price)
  • Advance Pricing Agreements (APAs) and mutual consensus
Taxation of the Digital Economy
  • Jurisdictional challenges for digital business models
  • Unilateral measures (e.g., Digital Service Taxes)
  • OECD’s Pillar One: New taxing rights and profit allocation rules
  • OECD’s Pillar Two: Global Minimum Tax (GloBE Rules)

Unit 4: Tax Treaties and Dispute Resolution

Model Conventions and Their Application
  • Detailed comparison of the OECD and UN Model Tax Conventions
  • Treaty interpretation and permanent establishment (PE) concept
  • Limitation on Benefits (LOB) and anti-abuse clauses
International Tax Controversy
  • Mechanisms for resolving double taxation (MAP, Arbitration)
  • Competent authority procedures and their effectiveness

Unit 5: Policy Lessons and Global Trends

Harmonization, Competition, and Cooperation
  • The dynamic interplay of tax competition and cooperative efforts
  • The role of international organizations (OECD, UN, IMF) in tax governance
  • Global tax transparency initiatives (CRS, FATCA)
  • Designing tax incentives in a global environment

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