32E30000 Tax Planning of International Enterprises Practical guide Assistant professor Tomi Viitala

2 Course schedule Venue E-127 (Arcadia building) at Mon April 11 Course introduction & framework for international tax planning Mon April 18 Dimensions of tax planning, OECD BEPS and EU developments Wed April 20 (TBC) Financing & tax planning (Guest speaker Jari Ahonen/Deloitte) Mon April 25 Tax planning of inbound investments into Finland (Guest speaker Lauri Finér/Helsinki University) Wed April 27 Transfer pricing methods and business model optimization (Guest speaker Petteri Rapo/Alder&Sound) Mon 2 May Transfer pricing of intangibles (Guest speaker Petteri Rapo/Alder&Sound) Wed 4 May Country-by-Country Reporting/Tax Footprint (Guest speaker Jarno Siivola/Metso) Wed 18 May Group work presentations

Learning objectives How to use the concepts of international corporate taxation and the role of taxation in the decision making process of the international enterprises  Selected building blocks of international tax planning as well as anti-avoidance provisions against aggressive tax planning are examined in light of the OECD BEPS (base erosion and profit shifting) and EU developments  Guest speakers bringing up topical issues and views on the topics 3

4 Passing the course Option 1: 100 % Book exam (1st on 25.5) Option 2: 50 % Book exam + 50 % essay Option 3: 50 % Group work + 50 % essay Option 1: 100 % Book exam (1st on 25.5) Readings: lecture notes + reading package 1 + choose 1 from reading packages 2-4 Option 2: 50 % Book exam + 50 % essay Readings: lecture notes + reading package 1 Essay: 3 pages on a topic of your choice covered by the course Essay should be submitted within two weeks after the book exam

5 Passing the course Option 3: 50 % Group work + 50 % essay Group work: a word report of 5 pages on a topic of your choice and a 15 min presentation on key findings, a group of 2-4 persons. Essay: 3 pages on a topic of your choice covered by the course Group work: should be prepared during the course and presented on 18 May Topic proposals: –Finnish interest deduction limitation rules: similarities and differences to the OECD BEPS approach? –Analyse tax footprints of 2 Finnish companies. What are the similarities and differences, what kind of ”tax story” they tell? –Three tiered TP documentation (master, local, country-by-country)? –Delineation of transactions for transfer pricing purposes? –Analyse one of the common tax planning techniques used in inbound investments into Finland. What are the tax benefits, what about risks?

Essays and group work Essay and group work respectively substitutes 50 % of the book exam (max. 10 points) The points will be based on –correctness, thoroughness and versality of points of view provided on the topic Agree the topic with the teacher by Keep with the deadlines –Essay: latest two weeks after the book exam –Group work: presentation 18 May, word report latest two weeks after the book exam 6

Reading packages (to be provided on MyCourses) Lecture notes Reading package 1 (Framework for and developments in international tax planning) –OECD Action Plan on Base Erosion and Profit Shifting, 2013 –European Commission: Study on Structures of Aggressive Tax Planning and Indicators, Final Report 2015 (pp and 89-91) –Hans van den Hurk: Starbucks vs the People (2014) Reading package 2 (Financing & tax planning) –Finér – Ylönen: Metal Ores in Tax-Driven Wealth Chains: A Case Study of Tax Planning in the Finnish Mining Sector (2016) pp –BEPS Action deliverable: Neutralizing the effects of hybrid mismatch arrangements (pp. 1-41) –BEPS Action 4 Final report: Limiting base erosion involving interest deductions and other financial payments (pp. 1-74) 7

Reading packages Reading package 3 (Transfer pricing & arm’s lenght principle) –BEPS Action 8-10 Final report: Aligning transfer pricing with Value creation (pp ) –Ylönen – Teivainen: Politics of Intra-Firm Trade:Corporate Price Planning and the Double Role of the Arm’s Length Principle (2015), pp Reading package 4 (Tax transparency) –BEPS Action 13 Final report: Transfer pricing documentation and country-by- country reporting (pp. 1-51) –Lecture slides: BEPS Country-by-Country Reporting International Transfer Pricing Seminar, Helsinki,10 November 2015 –European Commission: Summary of the responses to the public consultation on assessing the potential for further transparency on corporate income taxes,