• Course title: Introduction to Luxembourg Tax Law
• Number of ECTS: 0
• Course code: MADE4-1
• Module(s): Module 1 Luxembourg taxation
• Language: EN
• Mandatory: No

On completion of the course unit successful students will be able to (using action verbs):- Explain the systematics and general principles of Luxembourg tax law;- Complete a Luxembourg income tax declaration (natural and legal persons);- Apply the Luxembourg Income Tax Law to small case studies

The course gives an overview of Luxembourg tax law, focusing on personal income tax (PIT) and corporate income tax (CIT) law. It also includes sections on municipal business tax (MBT) and net wealth tax (NWT). The aim of the course is to acquaint students with the legal framework of Luxembourg income and wealth tax law and its systematics.

• Course title: International Tax Law I: General Principles and Systems
• Number of ECTS: 5
• Course code: MADE4-EITL-2
• Module(s): Module 2 International Taxation
• Language: EN
• Mandatory: Yes

On completion of the course unit successful students will be able to (using action verbs):

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Identify the causes of double taxation and remedies provided for by international instruments and mechanisms;

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Apply the principles and rules of the international tax system to solve complex cross-border tax cases;

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Explain the specifics of the US approach to international taxation.

This course builds on students’ basic knowledge of national and international tax law. It covers the fundamental structure of the international tax regime as well as its most important notions that underpin that system. It complements the course “International Taxation II – Allocation of Taxing Rights and Avoidance of Double Taxation”, which focusses on technical aspects of traditional international tax law. The course is divided among three teachers, Professor Werner Haslehner (WH) and two world-leading academic experts, Professor Alexander Rust (AR) and Professor Yariv Brauner (YB).

• Course title: EU Tax Law I – Fundamental Freedoms and State Aid
• Number of ECTS: 5
• Course code: MADE4-EITL-5
• Module(s): Module 3 EU Taxation
• Language: EN
• Mandatory: Yes

On completion of the course unit successful students will be able to (using action verbs):Identify the interaction of the four freedoms with direct taxation and the main problems and frictions that arise there from;-    Master the CJEU’s case law in the aforementioned thematic areas discussed in class;-    Understand the relationship between state aid law and tax law and estimate the impact of state aid law on national tax legislation;-     Comfortably navigate the steps necessary to decide whether a national measure needs to be notified to the Commission.

The course is addressed to students with a basic knowledge of tax law. Some basic notions of EU law and tax law will be briefly revised in the first classes in order to ensure a level playing field. The focus of the course is the interaction of the fundamental freedoms with direct taxation. Hence, the course will be predominantly based on the CJEU’s case law. Because of the impossibility to go through all cases pertaining to the aforementioned issues, we will present, examine and critically discuss ‘the landmark decisions’ of the CJEU as well as other ‘important’ cases from both a horizontal and a thematic perspective.  By way of introduction, the following EU and tax law topics will be briefly recapitulated (Prof. Katerina Pantazatou): –      The basic principles of EU law (e.g. the principle of conferral, the principle of subsidiarity and proportionality);-      The role of the EU institutions in direct taxation with special emphasis on the CJEU; –      Legislation in tax matters;-      Major provisions applicable to direct taxation;-      The four freedoms (scope, four step analysis; order of priority). Upon their introduction, these basic concepts will be discussed vis-a-vis the CJEU’s direct tax case law. While the analysis will be mostly ‘thematic’ (i.e. it will be built around the main problematic issues presented before the CJEU like taxation of cross-border workers), the aim of the course is to discuss the case law also from an evolutionary and analytical perspective in order to show the development of the relevant EU and tax law concepts in time and the particularities of tax law, in specific the notions of disparities and dislocations and the importance of the distinction between inbound and outbound situations for comparability purposes. Hence, the course will begin by providing a systematic and horizontal analysis of the aforementioned problems, while introducing the students to the case law. In specific, the following questions will be discussed (Prof. Pantazatou): –      What are non-discriminatory restrictions? What are disparities and what are dislocations? Which ones are covered by the fundamental freedoms?-      When are two situations (domestic vs. cross-border/ cross border v. cross-border/ different legal forms) comparable?-      What justifications and under what circumstances have been accepted by the Court?-      How does the proportionality test work in the given case law? The thematic analysis will focus on the following questions and the way they were treated by the CJEU: –      Personal income tax (Prof. Katerina Pantazatou)-      Tax planning, tax avoidance and tax abuse in the EU and the relevant case law (Prof. Ana Paula Dourado);-      Treatment of losses and group relief in the EU and the relevant case law (Prof. Katerina Pantazatou);-      Withholding taxes (Prof. Edoardo Traversa)-      Double taxation in the EU and the relevant case law (Prof. Leopoldo Parada). The course will also address the relationship between state aid and tax law. In this context, it will review the main General Court and CJEU case law, including the recent transfer pricing major profile cases (Prof. Katerina Pantazatou)Specifically, the course will:-        recapitulate the fundamental principles of state aid law before applying them to national taxation;-        analyse the four criteria to find illegal state aid as laid down in Article 107 TFEU;-        critically discuss the three-step test applied by the CJEU to fiscal state aid cases;reviews existing cases on aspects of corporate taxation, environmental taxation, transfer pricing, and hybrid mismatches

• Course title: Course 1 – Company Law and M&A
• Number of ECTS: 5
• Course code: MADE4-EITL-7
• Module(s): Module 4 – Investment Taxation
• Language: FR, EN
• Mandatory: Yes

• Course title: Course 1 – Tax policy
• Number of ECTS: 5
• Course code: MADE4-EITL-8
• Module(s): Module 5 – Elective courses
• Language: EN
• Mandatory: No

On completion of the course unit successful students will be able to (using action verbs):

Estimate the consequences of taxation on economic operator’s choices and thus the economy as a whole

Discuss positive and negative effects of certain policy choices at an academic level

Examine the basic economics of taxation

Identify and criticise ideas and proposals made in either an academic or political (real-world) context

This course provides an introduction into economic theory and concepts and how these relate to taxation. The course will teach the tools necessary to understand how taxation affects prices, saving and investment choices, distorts consumption patterns and work effort, relates to risk taking and the production and distribution of wealth within an economy. Students will thus acquire skills that enable them to ‘look behind the law’ and to scrutinise the complex legal incarnations of theoretical concepts in practice.  Furthermore, a thorough analysis of various taxes (including both practical examples from different countries and ‘blueprint’ concepts) will allow the students to understand the difficult choices that influence the practice of tax policy making and the unavoidable trade-off between differing economic, legal, political and philosophical ideals.  The course provides the students with an understanding of key design issues for all the main tax laws common around the world and will so enable them to evaluate and criticise the merits of practical tax reform concepts.

• Course title: Tax Practice Workshop
• Number of ECTS: 10
• Course code: MADE4-EITL-9
• Module(s): Module 6 – Final paper
• Language: EN
• Mandatory: No

On completion of the course unit successful students will be able to (using action verbs):Apply the knowledge acquired throughout the programme to practical problems that are frequently encountered in tax lawRespond to fact patterns described in a realistic and incomplete way in a professional and helpful mannerFind latest case law in Luxembourg and other jurisdictions to give answers to problems posed beyond the scope of the issues described in courses

This course has a dual aim: First, it consolidates the knowledge and skills acquired in all previous courses, in particular from the first semester, with practical exercises that both test students’ retention of the content of other classes and showcase their useful application in practice Second, it introduces particular topical subjects that are of particular practical relevance and have not been discussed in other classes, often because they have only become relevant during the academic year  The course is thus a key element towards the finalisation of students’ progress towards mastery of the taught subjects and an opportunity to ensure that they are up to date with latest developments in the law when they graduate.