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

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

3. How is it determined whether an individual is resident in the UK for tax purposes and why is that relevant?

4. Should the remittance basis for taxing certain individuals be abolished?

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

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

7. In what circumstances is a company incorporated outside the UK subject to UK taxation on all or some of its UK income or profits?

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

9. Is tax competition amongst states harmful?

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

11. Are controlled foreign company rules necessary? Is the UK CFC regime fit for purpose?

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

13. Are the EU State aid rules fit for purpose?

14. Describe how the fundamental freedoms under EU law are relevant to the taxation of cross-border business activities. What justifications can Member States raise to support tax measures that infringe these freedoms?