In order to follow this subject it is advisable to have a general knowledge of the tax system. In addition, knowledge of the functioning of international treaties is required

1.- Basic concepts of international taxation a) Taxation of worldwide and locally-sourced income. b) Legal and economic double taxation, and mechanisms of correction. 2.- Spanish rules on international taxation. a) Non-Residents Income Tax (IRNR): tax subject, taxable events, exemptions, taxable income and tax administration. b) Taxes on Personal Income (IRPF) and Corporate Income (IS). Taxation of global income in IRPF and IS. Domestic mechanisms to correct double taxation in IRPF and IS. 3.- Double Taxation Treaties (DTTs) a) Basic concepts. The models. Relationship domestic law-DTTs. DTTs interpretation and scope of application. b) Allocation rules. Active and passive income. c) Mechanisms to avoid double taxation. Exemption and credit. Non-discrimination issues d) Administrative matters (conciliation procedure, information Exchange and mutual assistance in tax compliance). 4.- International Tax Planning and anti-abuse tools a) Tax Treaty Abuse. Treaty Shopping and Rule Shopping b) Transfer pricing. c) Asset-holding companies and tax transparency. d) Hybrid financial instruments and matching rules. e) Indebtedness, thin capitalization and financial expenditures

International Taxation 1.- Basic concepts of international taxation a) Taxation of worldwide and locally-sourced income. Legal and economic double taxation, and mechanisms of correction. b) Anti-abuse rules c) Exchange of information mechanisms 2.- Double Taxation Conventions (DTCs) and the Multi-Lateral Convention a) Basic concepts. The models. Relationship domestic law-DTCs. DTCs interpretation and scope of application. b) Allocation rules. Active and passive income. c) Mechanisms to avoid double taxation. Exemption and credit. Non-discrimination issues 3.- International Tax Planning and general and targeted anti-avoidance rules (GAARs and TAARs) 4.- Dispute resolution mechanisms 5.- The digital economy and its impact on the allocation of taxing rights.

TEACHING ACTIVITIES BY MATTER AF1 Lecture AF2 Practice/Case AF3 Lecture-plus-practice AF6 Group work AF7 Students individual work TEACHING METHODOLOGIES BY MATTER MD1: Lecture in class by the professor aided by computer and audiovisual tools, in which the course¿s main concepts will be developed, and the main literature will be provided. MD2: Critical reading of the texts recommended by the professor: press articles, reports, manuals and/or academic articles, for their discussion in class, or to expand and consolidate the lessons of the course. MD3: Resolution of cases, problems, etc, provided by the professor, individually or in groups. MD4: Exposition and discussion in class, moderated by the professor, on topics regarding the contents of the course, as well as practical cases. MD5: Making of Works and reports individually or in groups. TUTORING: Students will have access to tutorials with the person responsible for coordinating the subject. With tutoring, it is intended to organize the teaching and learning processes that are based on the interaction between the student and the teacher in order to: (i) Guide the autonomous and group work of the students (ii) Deepen in different aspects of the subject (iii) Guide the academic and comprehensive training of the student. The tutorials will take place at the time and under the conditions determined by the teacher in Aula Global.