Part VI: International and European Union Tax

1. Does the source/residencedistinction for allocating taxing rights internationally make sense?

2. Whatoptions are available for reducing international double taxation in general? Illustratewith examples of how these various options are applied in the UK tax system.

3. How is itdetermined whether an individual is resident in the UK for tax purposes and whyis that relevant?

4. Should theremittance basis for taxing certain individuals be abolished?

5. How is itdetermined whether a company is ‘resident’ in the UK for purposes of theCorporation Tax Acts? Does this make sense?

6. In whatcircumstances is a company resident in the UK subject to tax on non-UK profits?

7. In whatcircumstances is a company incorporated outside the UK subject to UK taxationon all or some of its UK income or profits?

8. What is a‘permanent establishment’? What are the advantages and disadvantages of usingthis as threshold for allocating taxing rights on business income?

9. Is taxcompetition amongst states harmful?

10. What was theaim of the OECD/G20 BEPS project and was it a success?

11. Arecontrolled foreign company rules necessary? Is the UK CFC regime fit forpurpose?

12. Discussexamples of positive and negative harmonisation of tax rules in the EU.

13. Are the EUState aid rules fit for purpose?

14. Describehow the fundamental freedoms under EU law are relevant to the taxation ofcross-border business activities. What justifications can Member States raiseto support tax measures that infringe these freedoms?