Master in Global Taxation (LL.M./MsL) On the international stage you need more than domestic knowledge

NYU School of Law

This program offers a great opportunity for students to upgrade their knowledge and skills on international tax issues thanks to the study of the most updated trends and challenges of this global and new economy.

DURATION

10 Months

LANGUAGE

English

LOCATION

Madrid - New York

Program

Master

Format

Full-time

Intake

October

The Master in Global Taxation (LL.M./MsL) is an outstanding opportunity for students worldwide to upgrade their knowledge and skills on tax issues regarding multinationals and individuals thanks to the study of the most updated trends and challenges of this global and new economy. Its aim is to develop the most modern, truly global and practical international tax Master that can be found worldwide.

The program includes a certificate and one-week academic experience in Global Taxation in NYU School of Law, regarded as one of the most prestigious and selective law schools in the world.

               

OFFICIAL DEGREE

Students must fulfill the following requirements to be able to request the issuance of the Official University Degree upon completion of the Master Program.

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An enriching learning experience

This program has been designed to transform students into global tax professionals who are also excellent problem solvers and great business strategists. Our tax, legal and business core curriculum, is complemented by modules designed to develop soft skills and global awareness.

Our students leave IE prepared to work side by side with clients and different company stakeholders in the development of strategic plans. This transformation translates into our students becoming leaders in the international practice of tax and innovation on a global level.

International Tax Challenge

Students will team up to solve a complex practical case that will test all the tools learnt throughout the program. One or several students from the winning team will be granted an internship to work on the international taxation department of a Law Firm in Spain, subject to the internal selection process, availability and entry requirements of the receiving Law Firm.

"Taxes at the Top" Immersion Experience

This beyond-classroom experience seeks to introduce students to the world of “Top” International Tax advisors. Students will visit some of the most relevant players in the field who will give a practical and innovative approach to the exercise of international taxation.

Experience a week in NYU School of Law

Students will have the opportunity to undertake a one-week academic experience in Global Tax at one of the world's most prestigious law schools. Upon completion, students will receive a certificate from NYU School of Law.

Let´s talk taxes!

Dean Javier de Cendra speaks with Pablo Alarcón, Founding Partner of Alarcón Espinosa Abogados and Co-Director of the Master in Global Taxation, about the impact of globalization and technology on the taxation of multinationals. Check out the entire interview and learn more about important tax issues such as aggressive tax planning and the importance of fostering high ethical standards in law schools and the sector.

This module offers the introductory notions of Global taxation (mainly US and EU taxation), its legal framework, the basic models and treaties, such as the OECD Model, and basic rules of international private law.

Introduction to Global Taxation

The objective of the course is to provide a recent history of taxation, of points of connection and International bodies such as UE, OECD, UN, and others. Influential sources of law will be studied together with US Tax law principles. The learning process will be completed with the analysis of the current situation and public policies, trends and short term developments.

General Tax Framework

The course comprises the analysis of taxes as part of public policy and tax collection. It will include a first glimpse on direct and indirect taxes, custom duties, etc. The Standard terms applied in tax models will also be studied, together with an introduction to worldwide taxation and control.

Tax Treaties: The OECD Model

The objective of the course is to provide a comprehensive view of the history, principles and interpretation of the OECD Model. Specific features of the Model will be analyzed and special attention will be paid to special clauses. Other tax treaties will be discussed, such as ones dealing with inheritance tax and the multilateral treaty project BEPS 15.

EU Taxation

Students will be provided with tools to understand the principles of EU treaty affecting taxation, the concept of state aid and limits to tax benefits, the main tax directives and implementing rulings, the role of ECJ and main tax related resolutions, the limits of domestic anti-avoidance, the plan for consolidated taxation, tax protected industries, and the value and limits of tax rulings.

International Private Law

The objective of the course is to improve the students’ capabilities to understand and solve conflict of laws problems that typically arise in international business transactions. Although IE is based in Europe, students should improve their understanding of global conflict of laws problems, for instance, being aware about the exposure to being sued in jurisdictions such as the United States, Mexico, Brazil, etc. and understanding the conflict of laws developed in other jurisdictions of the world.

Introduction to US International Tax Issues

The course covers the general US international tax principles, subpart f and dividend tax credits, specialties of US treaties (LOB and others), CFC regulations and other anti-avoidance, classic US multinational structures, US tax for US citizens living abroad, US reporting and tax compliance.
The course is taught by IE together with the collaboration of NYU faculty, and forms part of the US Tax Regulation Certificate granted by NYU.

International tax planning is the backbone to international taxation. This module develops the most recent regulation affecting this topic, and offers students the most varied tools to develop tax planning strategies for multinationals, individuals and families, making a special mention to international VAT and other indirect taxes.

International Tax Planning for Multinationals

The course’s objective is to analyze the basic international business model and influence of tax. Students will study alternative legal and financial frameworks for international business, double taxation on dividends, tax planning instruments and vehicle, Holding companies, standard tax saving structures, taxation of international mergers and takeovers and the legitimate use of tax havens.

International VAT Law and other International Indirect Taxes

The course is designed to provide a comprehensive approach to international VAT, starting with its birth, the principles of the sixth directive (starting point and main changes to date), and VAT in international transactions and triangular operations. Additionally, some controversial situations involving VAT in the international markets will be considered as well as a special mention of VAT in the digital economy.

International Tax Planning for Individuals and Families

The course objective is to study the concept of tax residence, providing tools for the choosing of residence and to study Treaty tax break rules through case law. Furthermore, exit taxes worldwide will be considered with a special focus on taxation of performers and entertainers and basic tax planning for international individuals, international wealthy families, the use of Trusts in US and UK estate planning and principles and handling of expat taxation.

Transfer Pricing

The relevance of transfer pricing for multinational enterprises, how to determine a transfer price, how to apply the arm’s length principle, the difficulties of finding comparables, the application of transfer pricing methods and documentation obligations will be considered from a practical point of view and taking into account business perspectives and the tax administrations’ considerations during tax audits.

Aggressive international tax planning has derived in the need for tax specialists to be experts on the latest anti-avoidance mechanisms implemented by the international community. A very close attention will be paid to BEPS.

Anti-avoidance I: Principles and Framwork

The increasingly abuses on tax planning models have derived into tax practices that carry double non-taxation or less than single taxation situations. As such, this course deals with the concept of anti-avoidance rules in civil and common law, tax elusion, tax evasion and tax avoidance. The content is completed with the study of special anti-avoidance provisions together with their interpretation and limits and the analysis of general antiavoidance rulings.

Anti-avoidance II: BEPS

The course will focus on the origin and objectives of BEPS, the OECD list and EU Antiavoidance package, including the Directive about this topic, and a review of the most important BEPS studies and recommendations on:
- Digital economy,
- PE abuse
- CFC Rulings
- Treaty abuse
- Exchange of information
- Multinational treaty
A special mention will be made to the next steps to be taken on BEPS and the workings of the OECD to this respect.

During the past few years, great attention has been paid to aggressive tax planning. This module pays particular attention not only to risk assessment techniques, but also to the ethical component that must drive international tax planning. Furthermore, it goes into the strategies and regulation of international tax disputes.

Risk Assesment and Advisory Role

In an ever-changing business sphere, we have seen a rise in the cases of tax avoidance scandals carried by multinationals. To deal with this situation, tax advisors have to carry tax planning strategies according to strict ethical standards.
The course comprises a study of the concept of tax risks and different scenarios in which they may arise. By doing so, students will be given tools to carry effective risk assessments taking into consideration the professional responsibility and personal liability of tax advisors.

In this module the student will explore the most relevant industries in which international taxation plays a critical role, such as financial and capital markets, manufacturing, and real estate, among others. Special attention will be paid to taxation in the digital economy.

Tax Planning Models per Industry

Tax is a field of law relevant in all industries and transactions. Nonetheless, special attention will be paid to the main industries of influence, such as the manufacturing industries (particularly in respect to transfer pricing), finance and capital markets (use of debt), Digital economy (Licensing) and the Real estate business (debt and deferral).

An exceptional taxation lawyer needs to understand how its clients’ business works, and the external forces that may affect it. Hence, this module focuses on enhancing student’s understanding on accounting, strategic and financial management, economics and negotiation. Special attention is paid to the entrepreneurial skills necessary to succeed in business.

Accounting

This course will emphasize the understanding of how financial statements are created and how accounting decisions affect these statements. The course will teach the theory emphasizing the use of accounting as a tool for decision-making and problem solving.

Strategic Management

This strategy introductory course will introduce students to the mission and realities of general management in order to enable them to think strategically and effectively manage companies and business units.

Financial Management

This course helps students understand how Corporations create value and how to enhance it through every day strategies at all levels of the organization. This will be used to build their own powerful business vision.

Economics

The course will cover the most important economic theories and concepts that relate to the macroeconomic and microeconomic environment of businesses.

Negotiation

This program has been designed so that participants may learn the “art of negotiation” as an effective tool that they will be able to use throughout their professional careers and personal lives.

To be an integral professional, it demands the acquisition of knowledge and experiences beyond the formal legal arena. As such IE offers students tools to develop the interpersonal skills necessary to succeed in interviews, together with team building opportunities, lectures on current and groundbreaking fields, and international networking experiences beyond the classroom.

Accelerate

This series of sessions imparted by the Careers’ Department seeks to provide basic tools on CV building and interviews’ processes to students, in order to maximize their success when attending job interviews.

LAUNCH

The LAUNCH period consists on a number of introductory classes designed to immerse students in the case methodology and to enhance their collaborative and team spirit.

Global Forum

This series of sessions, carried by renowned professionals dealing with current topics in the areas of Corporate Law, Leadership skills, Compliance, Technology and Entrepreneurship, among others, provides updated knowledge to students, shaping them into well-rounded professionals.

Taxes on Top Immersion Experience

This beyond- classroom experience seeks to introduce students to the world of the “Top” International Tax advisors. As such, students will visit some of the most relevant players in the field who will give a practical and innovative approach to the exercise of international taxation.

International Tax Challenge

Students will team up to solve a complex practical case that will test all the tools learnt throughout the program. One or several students from the winning team will be granted an internship to work on the international taxation department of a Law firm in Spain, subject to the internal selection process, availability and entry requirements of the receiving law firm.

NYU Tax Certificate

In collaboration with NYU School of Law, we offer all students of the program a one-week trip to New York City where they will attend lectures imparted by New York University School of Law relating to:
• Fundamentals of US System and Rules of Inbound Taxation (GAAR, economic substance, source rules, US trade or business threshold, taxation on real property, among others),
• Outbound Planning (FTC Creditability, direct vs. indirect credit, FTC limitations, CFC rules, intangibles migration, etc.)
• Inbound Planning
• US Specific Treaty issues and transfer pricing issues (LOB clause and new US model)
• Compliance regulations (FATCA, W8/W9, FBAR, etc.)

One of the main pillars of IE’s educational model is based on innovation and investment in technological development. This module opens students to the world of technology and innovation and its role in the legal sphere.

Data Insights & Visualization

The purpose of this module is to give IE students a foundational set of hands-on skills that will allow them to work with data, which will give our students an advantage in the job market. The module will include topics like data management, data analytics and data visualization.

Technology for Innovation

The purpose of this module is to give our students an awareness of new and emerging technologies and the ability to visualize how these technologies might be applied to their specific field. This course will give them an innovative edge consistent with our corporate values of innovation and entrepreneurship.