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Law of international taxation


This course describes the rules and principles that together form the manner in which countries assert and limit their jurisdiction to tax cross-border flows of income and capital gains.

Governments, who have traditionally been very protective of their right to tax whatever amounts they think fit, are increasingly seeing the practical need to cooperate with each other.

This ensures that they continue to have solid international relations; their economies benefit from overseas investment; and they continue to collect what is considered to be a ‘fair amount of tax’.

This change in approach has been evidenced by, inter alia, initiatives that began with providing relief from double taxation. These initiatives have since moved on to exchanging taxpayer information with revenue authorities of other jurisdictions, and even to the point where governments acknowledge a need to assist other revenue authorities by collecting tax revenue on their behalf.

Module A: Introduction to international taxation


  • International tax law
  • Jurisdiction to tax
  • Residence and source
  • Methods of relief
  • History of international tax law

Module B: Double taxation conventions I


  • Types of double taxation convention
  • Interpretation of DTAs
  • Key provisions
  • Individuals
  • Articles 6, 13, 22 and 8

Module C: Double taxation conventions II


  • Businesses
  • Passive income
  • Non-discrimination
  • Cooperation between revenue authorities

Module D: Transfer pricing


  • Legal framework
  • Applying the arm's -length principle (ALP)
  • Aspect II: Transfer pricing methods
  • Special considerations and global formulary apportionment
  • Dispute resolution and documentation


Each module is assessed by a 45-minute unseen written exam.


It is strongly recommended that you attempt the modules in order.

How to apply

You can apply to study a module individually as a standalone unit or as part of a Postgraduate Certificate, Postgraduate Diploma or Master of Laws qualification.

These modules also contribute towards the following specialist pathways for Laws:

  • Commercial and corporate law
  • Comparative and foreign law
  • Corporate and securities law
  • Economic regulation
  • International business law
  • Tax law

Apply via Postgraduate Laws.

Academic Co-ordinator

Huigenia Ostik - Academic staff LLM

Huigenia Ostik

Huigenia Ostik has fourteen years experience researching, teaching and consulting on tax law and commercial law more generally. She is currently a Lecturer in Tax Law at the University of Auckland, New Zealand.

Her previous roles include Technical Module Leader (Tax) at Chartered Accountants Australia and New Zealand, lecturing at the University of Aberdeen and the University of the South Pacific and being an examiner for professional bodies. Huigenia has published articles on both domestic and international tax issues and has provided tax advice to high net worth individuals, government bodies and businesses. She has an LLB(Hons) from University College London and an LLM(Tax) Distinction from Queen Mary University of London.