This course is held in French but supported by documentation in English. It aims at providing students with an understanding of the basic issues and methodology of international tax law in the context of international projects management. The focus of the course lies on identifying tax exposures (withholding taxes, permanent establishment issues, transfer pricing, expatriates) and optimizing the tax structure of complex projects with an international background (tax optimization of financing, IP optimization models etc.). The students will be able to read and understand the structure and role of international double taxation treaties and apply such treaties to the projects they deal with.

After completing this course the students should:

• Be aware of major and usual international tax issues arising from international projects
• Be able to identify sources of risk and optimization
• Know how to read and apply a double taxation treaty in order to structure an international project properly from a tax point of view