Skip to main content
Unit of study_

LAWS6129: Taxation of Offshore Operations

2024 unit information

This is an advanced unit suitable for experienced tax practitioners who wish to extend their Australian tax law knowledge. The unit examines Australias rules for taxing the income earned from offshore operations. The unit examines the taxation of conducting business and holding investments offshore through foreign branches companies trusts partnerships and hybrid entities. It also examines the repatriation of profits from these entities the treatment of the cost of financing these operations and the consequences of offshore reorganisations and relocations. The unit examines in detail Australias CFC rules transferor trust regime, the FITO regime thin capitalisation rules and foreign hybrid rules. Further information about this unit is available in the Sydney Law School timetable https://canvas.sydney.edu.au/courses/4533/pages/postgraduate-lecture-timetable, unit of study outline https://www.sydney.edu.au/units and academic staff profile https://www.sydney.edu.au/law/about/our-people/academic-staff.html

Unit details and rules

Managing faculty or University school:

Law

Code LAWS6129
Academic unit Law
Credit points 6
Prerequisites:
? 
None
Corequisites:
? 
None
Prohibitions:
? 
None
Assumed knowledge:
? 
It is assumed that students undertaking this unit have an understanding of Australian income taxation law commensurate with that which would be obtained from completing undergraduate study in Australian taxation law or five years working with Australian tax law in a law or accounting practice in an industry role or in the Australian Taxation Office For students who do not have such knowledge or work experience they first should undertake LAWS6825 Introduction to Australian Business Tax before enrolling in this unit The Completion of LAWS6209 Australian International Taxation will provide students without such knowledge or work experience with additional knowledge and skills that will assists in successfully completing this unit

At the completion of this unit, you should be able to:

  • LO1. Critically analyse the policy underlying the legal rules on taxation of offshore operations
  • LO2. Analyse the current legal rules on taxation of offshore operations
  • LO3. Interpret and predict the implications of other legal rules on taxation applicable to offshore operations, including potential future developments
  • LO4. Apply the legal rules on taxation of offshore operations to resolve practical problems, incorporating the assessment of risks and identification of optimal solutions

Unit availability

This section lists the session, attendance modes and locations the unit is available in. There is a unit outline for each of the unit availabilities, which gives you information about the unit including assessment details and a schedule of weekly activities.

The outline is published 2 weeks before the first day of teaching. You can look at previous outlines for a guide to the details of a unit.

Session MoA ?  Location Outline ? 
Intensive June 2024
Block mode Camperdown/Darlington, Sydney
Session MoA ?  Location Outline ? 
Semester 1 2021
Normal evening Remote

Modes of attendance (MoA)

This refers to the Mode of attendance (MoA) for the unit as it appears when you’re selecting your units in Sydney Student. Find more information about modes of attendance on our website.