LL.M. in International Tax Law

The proposed 18-month programme encompasses two main areas and a mock negotiation.

The first area focuses on the fundamentals of International and EU tax law. In particular, attention is given to double taxation treaties, moving from the OECD Model to the UN Model with a look at the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). Moreover, the module concerning EU tax law investigates EU tax policy, fundamental freedoms, and the role of the European Court of Justice, approaching theory within an analysis of case-law. Finally, this area includes the Swiss international perspective with elements of Swiss domestic tax law, and an analysis of bilateral tax relations with the most relevant neighbouring countries (such as France, Germany, Italy, and Liechtenstein) as well as the US.

The second area, includes transfer pricing (fundamentals, practical application of TP rules, and dispute resolution) and a comparative analysis of Swiss and EU VAT. The last module addresses future trends in taxation, including topics such as the OECD Pillars (digital economy and minimum global taxation), the tax treatment of AI, robots, and cryptoassets, and the taxation of individuals’ mobility (remote work, privileged regimes, etc.) and corporate tax planning.

After an in-depth study of double taxation treaties and related issues, in the first main area a mock negotiation will take place. This is a exclusive teaching tool aiming at involving participants in a challenging simulation of the negotiation of a (part of) tax treaty. The simulation is based on a series of rounds, with written papers and feedback sessions.