Globalisation and the ease with which multinational corporations are able to shift profits across national borders have posed significant challenges to the existing international tax rules formulated in the 1920s. This course focuses on the international dimensions of corporate income tax law, with particular reference to the legal frameworks of Hong Kong and the PRC. The course commences with foundational concepts and policy issues in the international tax system, including the principles of jurisdiction to tax and the double taxation problem. It then explores international tax planning and avoidance strategies employed by multinational enterprises, as well as tax competition among governments in the globalised economy. Country responses to both problems of double taxation and tax minimisation schemes, including bilateral and multilateral treaties, anti-avoidance rules and international efforts against base erosion and profit shifting (BEPS) are reviewed. Finally, the course considers challenges posed by the digital economy and recent proposals and policy responses at both national and international levels.

The course will enhance study in other areas of international law and commercial law and prepare students for a career in a wide range of global employment destinations, including but not limited to legal profession, legal practice in accountancy, house company counsel and government agencies. Students are not expected to have prior knowledge of tax law.

The course leader will announce whether the examination will be closed book or open book. The use of Generative AI tools is not allowed.

Applicable to students admitted before Semester A 2022/23 and in Semester A 2024/25 & thereafter

Students must obtain a minimum mark of 40% in the final examination and an overall mark of 40% in order to pass the course.

Applicable to students admitted from Semester A 2022/23 to Summer Term 2024

Students must obtain a minimum mark of 50% in the final examination and an overall mark of 50% in order to pass the course.