MSc in Taxation (Part Time)

The Ethical Issues in Tax Practice course focuses on some of the ethical issues that arise for those involved in the tax world, whether as tax advisors, in-house tax counsel, tax officials, or tax policy makers. The emphasis is on the classroom discussion of several scenarios that raise ethical issues. Guests are invited to the class to speak on related issues, including corporate social responsibility, and on the limits of acceptable tax avoidance. It is an opportunity for tax professionals (or potential tax professionals) to work through and think through some of the potential ethical issues they will face (or may already have faced) in practice. The course is taught by Visiting Professor Philip Baker KC, Emeritus Professor Judith Freedman, Hans Gribnau, Anne Fairpo and Ekow Egha.

The course EU Tax Law will enable students to develop an in-depth understanding of European Union (EU) tax law and policy in the global context. This course will provide a comprehensive overview of the key aspects necessary for understanding how EU law affects investors and other economically active persons and entities within the EU and from third countries; as well as demonstrating how the EU’s tax policies are influenced by and shape global tax developments.

The programme will include the study of:

• •The primary law of the European Union and the effects it has on Member States’ direct taxation through the fundamental freedoms. This part will focus on landmark cases and several case studies which illustrate the impact of EU law on national tax systems, including exit taxation and anti-avoidance cases. Both the examples of the application of the freedoms within the territory of the EU/EEA and in third-country scenarios will be addressed. 
• The interaction between the international and European legal order in the tax context. The relationship between various types of legal instruments will be covered, including possible tensions between the Anti-Avoidance Directive and bilateral tax treaties and the application of the OECD’s Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting in the EU.
• EU fiscal state aid. This part will offer an overview of fundamental features of the EU fiscal state aid regime, its impact on tax rulings by EU Member States and an in-depth inquiry into the Apple case.
• The EU secondary legislation which facilitates cross-border capital flows (the Parent-Subsidiary Directive and the Interest and Royalties Directive), tackles abusive tax practices (the Anti-Avoidance Directive), stimulates administrative cooperation (the Directives on Administrative Cooperation in Tax Matters) and introduces an obligation on Member States to arrive at a resolution of all disputes that originate in bilateral tax treaties (Directive on Tax Dispute Resolution) will be discussed.
• Non-binding measures (the so-called “soft law”), including those aimed at tackling “harmful tax competition” and the promotion of good tax governance in third countries through the “black” and “grey” lists of non-cooperative jurisdictions. 
• Current issues in EU tax law and ongoing policy work, including the proposed harmonisation of corporate tax base and the introduction of formulary apportionment (Directive on Common Consolidated Corporate Tax Base), and the initiative on the taxation of the digitalised economy.

The course is taught by Dr Anzhela Cédelle, OEDC and others.

The International Tax Reform, The Two Pillar Solution course will cover the G20/OECD Inclusive Framework’s Two Pillar Solution. It will look at the main mechanics of the two pillars and also examine their underlying principles and policy objectives. It asks whether these objectives had been met and whether the reform would lead to a “good” international tax system. Alternative reforms were also considered. The course is led by Professor John Vella and Professor Neils Johannesen, with guest teaching by Richard Collier and Heydon Wardell-Burrus.

The Transfer Pricing course is concerned with the arm’s length principle and its application in the form of transfer pricing and profit attribution rules. The course provides an overview of transfer pricing and profit attribution from both a theoretical and practical perspective using case studies to illustrate the key principles, with a focus on the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations and the OECD’s guidance on PE attribution including the 2010 Report on the Attribution of Profits to Permanent Establishments. The course will consider the current debate on transfer pricing and profit attribution with a number of topical examples and the major conceptual, technical and practical problems of the income allocation rules will also be an especial area of focus.

The course includes the following topics:

• Fundamental Sources
• The Arm’s Length Principle and Comparability
• Functional Analysis
• Transfer Pricing Methods
• Comparability analyses in practice
• Intra-group services
• Risk and capital
• Issues raised by minimal function entities
• Financing
• Intangible property
• Business restructurings
• Permanent Establishments
• Compliance issues
• Avoiding Double Taxation/Dispute Resolution
• The future of the income allocation rules/arm’s length principle

The course is taught by Dr Richard Collier, Associate Fellow at Saïd Business School and Professor John Vella

The Rereading Classic Texts in Tax Law & Policy course will explore issues of topical importance in the field of taxation. The content will vary from year-to-year, and the course will be taught primarily by visiting lecturers, with contributions from Oxford-based academics.

Tax law is at a crossroads. Dramatic changes over the past years on the national, regional, and global levels have yielded substantial challenges for tax law and policy. These changes have brought to the forefront big questions on the normative and practical levels, domestically and internationally. Classic dilemmas of increasing welfare versus (re)distributing it have intensified, while new dilemmas of membership in democratic societies, tax competition, and international cooperation have emerged.
In this course we will go back to some of the most influential articles, books, reports and cases on various aspects of tax law and policy (e.g., what is income, tax and inequality, tax expenditures, taxing women, competition v. cooperation and global justice). We will read these classics with a critical eye, evaluate their contributions, confront them with their critics, and examine their relevance to contemporary times and the issues currently at stake. 

The course will employ a variety of normative considerations – justice, efficiency, personhood and democratic participation – and will engage with methods and concepts that often inform other areas of law as well as other disciplines, but no prior knowledge of any of the above is required.

The course will be taught by Professor Tsilly Dagan with guest lecturers Linda Sugin, Fordham Law School, Reuven Avi-Yoanh, University of Michigan School of Law and others.

The Tax and Development course will explore the role of taxation in the governance and economies of emerging and developing countries. We will discuss the role of taxes in state building and explain how tax systems of emerging and developing countries evolved over time.  We will explore the challenges such countries face in pursuing the classic goals of taxation, namely justice and efficiency, and consider the impact of increasing globalization and tax competition on the ability of LDCs to promote those goals. We look at the interaction of states’ tax policies with the policies of other (developed as well as emerging and developing) countries in bilateral tax treaties and consider the dynamics of such treaty negotiations. Finally, we will consider the impact of current multilateral initiatives for global reform of the taxation of multinational enterprises, of previous recent reforms such as the OECD/G20 Base Erosion and Profit Shifting project, and of evolving international cooperation—on tax systems in developing countries. We will conclude by taking an in-depth look at Sub-Saharan countries, using these countries as a summary case study.

The course will be led by Professor Tsilly Dagan, and Professor Vicki Perry (Georgetown University) with guest speakers from various developing countries.

The Tax and Public Policy course provides students with the essential tools to assess tax policy, with a particular emphasis on economic analysis. After discussing where economic analysis fits in the complete toolbox for assessing tax policy, students will be taught the essential tools from economic analysis in some detail. Having equipped students with these tools, the course then guides them through some fundamental issues in tax policy design. A number of cases studies are using during the course.

This is an elective course. Issues of tax policy will be considered in other compulsory and elective courses on the MSc. However, this course will cover these various issues in tax policy in a coherent and more detailed manner and with a greater emphasis on economic analysis. 

The course includes the following topics:
•    Tax Design and the Complete Toolbox
•    Economic Tools and /Concepts (including efficiency and optimal tax theory)
•    Some Fundamental Tax Policy Choices (including tax base, taxation of capital, rents)
•    Corporation Tax Policy

The course is taught by Professor Michael Devereux, Professor John Vella and Professor Neils Johannesen.

The Tax Treaties course focuses on the operation of double taxation conventions (more colloquially referred to as “tax treaties” and often abbreviated as “DTCs”). The emphasis is on the interpretation and application of DTCs, though students will also learn something about the negotiation of DTCs.

The course includes the following topics:

• Introduction to the structure and operation of the principal model DTCs – the OECD Model Tax Convention (“MTC”) and the UN MTC
• General provisions and definitions – especially the definitions of “resident” and “permanent establishment”
• Business profits – Arts. 7 and 9 OECD MTC
• Passive income – Arts. 10, 11, and 12 OECD MTC
• Individuals – Arts. 15, 16, 17 and 18 OECD MTC
• Methods of relief from double taxation – Art. 23 OECD MTC
• Non-discrimination – Art. 24 OECD MTC
• Settlement of international fiscal disputes – mutual agreement procedure – Art. 25 OECD MTC
• The future role of DTCs

First year students are strongly encouraged to attend Tax Treaties, as it is a foundation for many of the other electives.

The course is taught by Visiting Professor Philip Baker KC.

The US International Tax course covers the principal features of United States federal income taxation of cross-border activities, including both inbound and outbound transactions, and both corporate and individual taxpayers. The aim is to provide students with a working knowledge of US tax concepts and terminology relevant to international transactions, as well as the main tax issues that arise under US law in respect of cross-border trade and investment. US income tax treaties and administrative practices are also covered, along with an overview of current US international tax policy initiatives in Congress and the Treasury Department.

The course is taught by Professor Glen Loutzenhiser, Professor Susan Morse, The University of Texas, Stephen E Shay, Senior Lecturer on Law, Harvard Law School and Heydon Wardell-Burrus.

• James Bullock Scholarship: £5,000 over the two years
• Field Court Tax Chambers Scholarship: three awards for one year (number of awards and amount varies each year)
• One Full-fees needs based financial assistance award for 1st year students

Find out more about all scholarships from the Faculty of Law.

Field Court Tax Chambers prize for best overall performance in the MSc in Taxation

Gray's Inn Tax Chambers prize in Tax Principles and Policy

Best performance by a non-degree student

A Law Faculty prize in all other courses

• Professor Tsilly Dagan, Faculty of Law

• Professor Michael Devereux, Centre for Business Taxation

• Professor Glen Loutzenhiser, Faculty of Law

• Professor John Vella, Faculty of Law and the Centre for Business Taxation

Course Administrator: Liz Gresham, Faculty of Law

Administrator for Alumni, Events and Teaching Support: Agata Dybisz, Faculty of Law

• Philip Baker KC, OBE, Field Court Tax Chambers, Course Co-founder and Visiting Professor, Faculty of Law
• Paul Brice, Departmental Lecturer
• Dr Anzhela Cédelle (née Yevgenyeva)
• Emma Chamberlain, Barrister, Pump Court Tax Chambers and Visiting Professor, Faculty of Law
• Simon Douglas, Associate Professor of Law, Faculty of Law
• Emeritus Professor Judith Freedman, Faculty of Law and Centre for Business Taxation 

Oxford University has strong links with a world-wide network of leading academics and practitioners. Teachers participating in the teaching have included the following:

• Professor Reuven Avi-Yonah, University of Michigan
• Professor Jennifer Blouin, University of Pennsylvania
• Dr Meghan Campbell, University of Birmingham
• Dr Richard Collier, Associate Fellow at Saïd Business School
• Professor Rita de la Feria, Leeds University
• Professor David Duff, University of British Columbia
• Professor Joachim Englisch, University of Münster
• Domonic Foulkes, Davis Polk
• Malcom Gammie KC, One Essex Court
• Hans Gribnau, Tilburg University
• Dr Irem Guceri, Research Fellow at the Oxford University Centre for Business Taxation
• Professor Peter Harris, University of Cambridge
• Dr Martin Hearson, London School of Economics and Political Science
• Professor Neils Johannesen, University of Copenhagen
• Professor Susan Morse, The University of Texas
• Jonathan Peacock KC, 11 New Square
• Victoria Perry, Georgetown University
• Alice Pirlot, Assistant Professor, Geneva Graduate Institute
• Philip Ridgway, Barrister, Temple Tax Chambers
• Michael Ridsdale, Tax Partner, Wedlake Bell LLP
• Stephen E Shay, Senior Tax Fellow, Boston College Law School
• Professor Linda Sugin, Fordham University
• Professor Edoardo Traversa, UCLouvain
• Jeff VanderWolk, OECD Centre for Tax Policy and Administration
• Professor Richard Vann, University of Sydney
• Dr Adam Zalasiński, European Commission

Leading academics and practitioners are involved in the governance of the MSc in Taxation, including:

• Philip Baker KC, OBE, Field Court Tax Chambers, Course Co-founder and Visiting Professor, Faculty of Law
• Emeritus Professor Judith Freedman, Faculty of Law and Centre for Business Taxation
• Richard Collier, Associate Fellow at Saïd Business School, formerly a Tax Partner at PwC
• Bill Dodwell, Tax writer and policy adviser at the Office of Tax Simplification, formerly Head of Tax Policy at Deloitte
• Ekow Eghan, South Africa Leader, Ernst and Young
• Liesl Fichardt, Partner, Quinn Emanuel Urquhart & Sullivan LLP
• Giorgia Maffini, PricewaterhouseCoopers