Outline

Overview

This unit is designed to study the policy, detailed rules and practical application of Australia's international tax treaties against the background of the OECD Model Tax Convention on Income and on Capital. Upon successful completion of this unit a student should have an advanced understanding of the policies underlying the Australian tax treaty position in relation to the taxation of various kinds of income, as well as a detailed knowledge of the law applicable to interpretation of Australia's treaties. The unit includes a study of: principles of tax treaties; interpretation of tax treaties; and selected articles of the OECD Model and Australian tax treaties. Refer to the Sydney Law School timetable - https://canvas.sydney.edu.au/courses/4533/pages/postgraduate-lecture-timetable

Unit details and rules

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. Students who do not have such knowledge or work experience should undertake LAWS6825 Fundamentals of Australian Taxation before enrolling in other units. For students who have not studied Australian law it is recommended that they undertake LAWS6252 Legal Reasoning and the Common Law System before enrolling in LAWS6825 and 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 assist in successfully completing this unit
Available to study abroad and exchange students	No

Teaching staff

Coordinator	Michael Dirkis, michael.dirkis@sydney.edu.au

Assessment

The census date for this unit availability is 1 May 2026

Details
Criteria

Type	Description	Weight	Due	Length	Use of AI
Written exam	Final exam (60%) On-Campus, handwritten exam	60%	Formal exam period	2 hours	AI prohibited
Outcomes assessed:
Contribution	Structured class participation (10%) Leading class discussion	10%	Multiple weeks	Ongoing	AI allowed
Outcomes assessed:
Written work	(Alternative) Capstone proposal (0%) 500-word topic proposal	0%	Week 01 Due date: 13 Apr 2026 at 23:59 Closing date: 27 Apr 2026	500 words	AI allowed
Outcomes assessed:
Out-of-class quiz	Early feedback task (0%) Multiple choice	0%	Week 03 Due date: 27 Apr 2026 at 23:59	No time limit	AI allowed
Outcomes assessed:
Written test	In-class test (30%) Supervised in-class test	30%	Week 04 Due date: 04 May 2026 at 09:00	1 hour	AI prohibited
Outcomes assessed:
Written work	(Alternative) Capstone essay (60%) (Alternative) Capstone essay (60%)	0%	Week 09 Due date: 09 Jun 2026 at 23:59 Closing date: 23 Jun 2025	7000 words / 7 weeks	AI allowed
Outcomes assessed:
= early feedback task ?

Assessment summary

Early Feedback Task (0%) -This unit includes an Early Feedback Task that is designed to provide students with timely insights into their understanding and engagement with the unit content. The Early Feedback Task in this unit is a multiple-choice online assessment drawing on assumed knowledge and materials from Day 1. The task will be available on Canvas from 27 April 9.00am to 11.59pm 2026, Sydney Australia time. Students will be provided with immediate automated feedback upon completion of the task.

Structured class participation (10%) – Students will lead the class discussion for one session. This will be allocated prior to the commencement of the unit and the allocated student is required to lead the class discussion under the lecturer's questioning. They will be assessed against the Class Participation Assessment Rubric.
Students who are unable to make their allocated class must apply for Special Consideration. A failure to lead the class discussion in the allocated class will result in 0/10 for this assessment and may lead to an Absent Fail grade.
The outcome of a successful special consideration application is an alternative assessment, such as a viva voce (oral test), that has been designed to meet the same learning outcomes.

In-class test (30%) – The test will begin at 9.00am on 4 May 2026 Sydney, Australia time. It will be an open book test (hard copy/printed materials only, no electronic devices) in the form of problem style questions. It is a handwritten pen and paper test. You will have 1 hour of writing time plus 15 minutes of reading time to prepare your responses. The outcome of a successful special consideration application is a replacement test. The replacement test may be delivered via an alternative assessment, such as a viva voce (oral test), that has been designed to meet the same learning outcomes as the original test. The format of the alternative assessment will be determined by the unit coordinator.

Final exam (60%) – The Final Exam will be held on-campus and supervised. It will be an open book exam (hard copy/printed materials only, no electronic devices) in the form of problem style questions. You will have 2 hours of writing time plus 30 minutes of reading time to prepare your responses. The outcome of a successful special consideration application is a replacement test that may be delivered via an alternative assessment, such as a viva voce (oral test), that has been designed to meet the same learning outcomes as the original test. The format of the alternative assessment will be determined by the unit coordinator.

The supervised final exam will be held on-campus during the week beginning Tuesday, 9 June 2026. The exam timetable will be released by the Exams Office in due course. For further information, please refer to Exam Timetables.

Alternative Capstone proposal and essay - LLM students who are undertaking this unit towards the end of their degree, and need a capstone experience to complete their degree, must apply to the unit coordinator to undertake the assessment option of a Capstone Essay.

Students wishing to take up this option are required to submit a 500-word topic proposal via Canvas by 11.59pm on 13 April 2026 Sydney, Australia time.

Your essay topic should respond to the material covered in the present unit. However, at the same time, in order to serve as a capstone for your LLM, it should build upon the learning that has taken place during your LLM studies more generally.

The Capstone Essay will replace the final exam which is worth 60% of your marks for the unit. The Capstone Essay must be 7000 words and is due at 11.59pm 9 June 2026 Sydney, Australia time.

An oral defence of the Capstone will be held within two weeks of submission. The final mark will be determined taking into account both the written material and the oral defence.

The total word count for the Capstone essay will include all headings, footnotes and any bibliography etc. No penalty will apply if you exceed the word limit but any words beyond this limit will NOT be read or marked.

Referencing: The Sydney Law School expects you to use the Australian Guide to Legal Citation (4th edition, 2018) for your footnoting style, although you should confirm this with your lecturer. A link to the library website where this is set out comprehensively is available at Referencing and Citation Styles: AGLC4.

Special consideration: Successful grants of Special Consideration may involve alternative tasks, as appropriate.

Assessment requirements to pass a unit of study: A student must make a genuine attempt at all assessment tasks set out in this Unit of Study in order to obtain a Pass mark and grade (or above); otherwise an Absent Fail grade will be recorded as the student’s result for this Unit of Study. Please note that as the EFT is an early diagnostic tool, this task is not included in the final grade for the unit.

Assessment criteria

The University awards common result grades, set out in the Coursework Policy 2021 (Schedule 1).

As a general guide, a high distinction indicates work of an exceptional standard, a distinction a very high standard, a credit a good standard, and a pass an acceptable standard.

Result name	Mark range	Description
High distinction	85 - 100	Completely answers the question. Contains striking originality of approach or analysis. Demonstrates exhaustive or innovative research (where independent research required). Exceptionally well written, structured and expressed. Is otherwise exceptional in some way.
Distinction	75 - 84	Completely answers the question. Achieves a critical and evaluative approach to the issues. Content and structure is well organised in support of the argument. Demonstrates extensive research and analysis to support a well-documented argument. Generally well expressed and free from errors. Has a clear structure and is well articulated.
Credit	65 - 74	Covers main issues fairly well in answering the question. Contains no significant errors. Demonstrates an attempted critical approach to the issues. Demonstrates reasonably sound research and analysis in addressing the key issues. Has a clear structure and reasonably clear expression.
Pass	50 - 64	Identifies the key issues, but does not follow through with a reasoned argument. Contains some significant errors. Displays satisfactory engagement with the key issues. Offers descriptive summary of material relevant to the question. Superficial use of material, and may display a tendency to paraphrase. Demonstrates little evidence of in-depth research or analysis. Adequate expression. Demonstrates the minimum level of competence and satisfies the requirements to proceed to higher-level studies.
Fail	0 - 49	Does not answer the question. Contains significant or numerous errors. Few or no identifiable arguments. Content that is inappropriate or irrelevant. Lack of research or analysis. Difficult or impossible to understand through poor grammar, expression or structure. Overall, does not demonstrate the minimum level of competence in the assessment.

For more information see guide to grades.

Use of generative artificial intelligence (AI)

You can use generative AI tools for open assessments. Restrictions on AI use apply to secure, supervised assessments used to confirm if students have met specific learning outcomes.

Refer to the assessment table above to see if AI is allowed, for assessments in this unit and check Canvas for full instructions on assessment tasks and AI use.

If you use AI, you must always acknowledge it. Misusing AI may lead to a breach of the Academic Integrity Policy.

Visit the Current Students website for more information on AI in assessments, including details on how to acknowledge its use.

Late submission

In accordance with University policy, these penalties apply when written work is submitted after 11:59pm on the due date:

Deduction of 5% of the maximum mark for each calendar day after the due date.
After ten calendar days late, a mark of zero will be awarded.

This unit has an exception to the standard University policy or supplementary information has been provided by the unit coordinator. This information is displayed below:

Test and exam: Late penalties do not apply to exams and tests. Capstone essay: The late submission of a piece of assessment, without an approved extension, will attract a penalty of 10% of the total marks available for the piece of assessment per 24 hours or part thereof, after the due time on the due date.

Academic integrity

The University expects students to act ethically and honestly and will treat all allegations of academic integrity breaches seriously.

Our website provides information on academic integrity and the resources available to all students. This includes advice on how to avoid common breaches of academic integrity. Ensure that you have completed the Academic Honesty Education Module (AHEM) which is mandatory for all commencing coursework students

Penalties for serious breaches can significantly impact your studies and your career after graduation. It is important that you speak with your unit coordinator if you need help with completing assessments.

Visit the Current Students website for more information on AI in assessments, including details on how to acknowledge its use.

Learning support

Simple extensions

If you encounter a problem submitting your work on time, you may be able to apply for an extension of five calendar days through a simple extension.  The application process will be different depending on the type of assessment and extensions cannot be granted for some assessment types like exams.

Special consideration

If exceptional circumstances mean you can’t complete an assessment, you need consideration for a longer period of time, or if you have essential commitments which impact your performance in an assessment, you may be eligible for special consideration or special arrangements.

Special consideration applications will not be affected by a simple extension application.

Using AI responsibly

Co-created with students, AI in Education includes lots of helpful examples of how students use generative AI tools to support their learning. It explains how generative AI works, the different tools available and how to use them responsibly and productively.

Support for students

The Support for Students Policy reflects the University’s commitment to supporting students in their academic journey and making the University safe for students. It is important that you read and understand this policy so that you are familiar with the range of support services available to you and understand how to engage with them.

The University uses email as its primary source of communication with students who need support under the Support for Students Policy. Make sure you check your University email regularly and respond to any communications received from the University.

Learning resources and detailed information about weekly assessment and learning activities can be accessed via Canvas. It is essential that you visit your unit of study Canvas site to ensure you are up to date with all of your tasks.

If you are having difficulties completing your studies, or are feeling unsure about your progress, we are here to help. You can access the support services offered by the University at any time:

Support and Services (including health and wellbeing services, financial support and learning support)
Course planning and administration
Meet with an Academic Adviser

Weekly schedule

WK	Topic	Learning activity
Week 03	Policy, history and context of the OECD and UN Models	Seminar (5 hr)
Week 03	Taxes covered and definitions, particularly resident and permanent establishment	Seminar (6 hr)
Week 04	Business and investment income	Seminar (6 hr)
Week 04	Services related income	Seminar (4 hr)
Week 05	Relief of double taxation, fiscally transparent entities, saving clause, administrative cooperation, treaty abuse	Seminar (5 hr)

Attendance and class requirements

Attendance: All students are required to attend 70% of classes to satisfy the pass requirements for this unit. Failure to meet this requirement will result in an Absent Fail grade being recorded as the student’s result for this unit (see The University of Sydney Law School Resolutions: Coursework Awards cl 11).

Study commitment

Typically, there is a minimum expectation of 1.5-2 hours of student effort per week per credit point for units of study offered over a full semester. For a 6 credit point unit, this equates to roughly 120-150 hours of student effort in total.

Required readings

Text

C. John Taylor, et al, Australian International Income Taxation: Policy, Principles and Practice (1st ed, 2021) Thomson Reuters, Sydney, Ch 6, pp 339-491

Other resources

OECD Model Tax Convention on Income and on Capital (2025 Condensed Version) (OECD Model). This is available from OECD iLibrary via Library databases
UN Model Double Taxation Convention between Developed and Developing Countries (2021 UN Model).

Learning outcomes

Learning outcomes are what students know, understand and are able to do on completion of a unit of study. They are aligned with the University's graduate qualities and are assessed as part of the curriculum.

Outcomes
Graduate qualities

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

LO1. Critically analyse the detailed rules and underlying policies applied to tax treaties.
LO2. Create and substantiate/justify analyses of the current legal rules on taxation
LO3. Evaluate the efficacy of current taxation rules and propose viable alternatives.
LO4. Apply legal rules on taxation to resolve complex legal and taxation scenarios.

Graduate qualities

The graduate qualities are the qualities and skills that all University of Sydney graduates must demonstrate on successful completion of an award course. As a future Sydney graduate, the set of qualities have been designed to equip you for the contemporary world.

GQ1	Depth of disciplinary expertise Deep disciplinary expertise is the ability to integrate and rigorously apply knowledge, understanding and skills of a recognised discipline defined by scholarly activity, as well as familiarity with evolving practice of the discipline.
GQ2	Critical thinking and problem solving Critical thinking and problem solving are the questioning of ideas, evidence and assumptions in order to propose and evaluate hypotheses or alternative arguments before formulating a conclusion or a solution to an identified problem.
GQ3	Oral and written communication Effective communication, in both oral and written form, is the clear exchange of meaning in a manner that is appropriate to audience and context.
GQ4	Information and digital literacy Information and digital literacy is the ability to locate, interpret, evaluate, manage, adapt, integrate, create and convey information using appropriate resources, tools and strategies.
GQ5	Inventiveness Generating novel ideas and solutions.
GQ6	Cultural competence Cultural Competence is the ability to actively, ethically, respectfully, and successfully engage across and between cultures. In the Australian context, this includes and celebrates Aboriginal and Torres Strait Islander cultures, knowledge systems, and a mature understanding of contemporary issues.
GQ7	Interdisciplinary effectiveness Interdisciplinary effectiveness is the integration and synthesis of multiple viewpoints and practices, working effectively across disciplinary boundaries.
GQ8	Integrated professional, ethical, and personal identity An integrated professional, ethical and personal identity is understanding the interaction between one’s personal and professional selves in an ethical context.
GQ9	Influence Engaging others in a process, idea or vision.

Outcome map

Learning outcomes	Graduate qualities
Learning outcomes

Responding to student feedback

This section outlines changes made to this unit following staff and student reviews.

The assessment has been updated in line with the new assessment framework

Disclaimer

Important: the University of Sydney regularly reviews units of study and reserves the right to change the units of study available annually. To stay up to date on available study options, including unit of study details and availability, refer to the relevant handbook.

To help you understand common terms that we use at the University, we offer an online glossary.

Current students

Overview

Overview

Unit details and rules

Teaching staff

Assessment

Assessment

Assessment summary

Assessment criteria

Use of generative artificial intelligence (AI)

Late submission

Academic integrity

Learning support

Learning support

Simple extensions

Special consideration

Using AI responsibly

Support for students

Weekly schedule

Weekly schedule

Attendance and class requirements

Study commitment

Required readings

Learning outcomes

Learning outcomes

Graduate qualities

Outcome map

Responding to student feedback

Responding to student feedback

Disclaimer

On this page

Useful links

LAWS6177: Tax Treaties

Semester 1b, 2026 [Block mode] - Camperdown/Darlington, Sydney

Overview

Overview

Unit details and rules

Teaching staff

Assessment

Assessment

Assessment summary

Assessment criteria

Use of generative artificial intelligence (AI)

Late submission

Academic integrity

Learning support

Learning support

Simple extensions

Special consideration

Using AI responsibly

Support for students

Weekly schedule

Weekly schedule

Attendance and class requirements

Study commitment

Required readings

Learning outcomes

Learning outcomes

Graduate qualities

Outcome map

Responding to student feedback

Responding to student feedback

Disclaimer

On this page

Useful links