Eduardo Baistrocchi

This course is available on the LLM (extended part-time), LLM (full-time) and University of Pennsylvania Law School LLM Visiting Students. This course is freely available as an outside option to students on other programmes where regulations permit. It does not require permission. This course uses controlled access as part of the course selection process. For information on controlled access courses, including eligibility, application processes, deadlines, and departmental contact details, please refer to the Controlled Access Courses webpage.

How to apply: Priority will be given initially to LLM, MSc Regulation and MSc Law and Finance students on a first-come-first-served allocation.

Spaces permitting, requests from all other students will be processed on the same first-come-first-served allocation from 10am on Thursday 1 October 2026

By submitting an application, students are confirming that they meet any pre-requisites specified. Providing an additional written statement will not aid a student's chances of being accepted onto a course, and statements are not read.

Deadline for application: Not applicable

For queries contact: Law.llm@lse.ac.uk

This course provides an in-depth examination of the taxation principles applicable to corporate finance transactions. Students will develop an understanding of the tax treatment of various financial instruments and corporate structures, equipping them with the analytical skills necessary to navigate complex tax issues in corporate finance.

Key topics include transfer pricing and the limits of the conduct-based approach; the taxation of debt versus equity financing; and the tax implications of dividends and other distributions. The course also explores the tax considerations surrounding corporate reorganisations, including share exchanges, takeovers, bonus issues, and rights issues.

Further areas of study include the taxation of loan relationships, deemed loan relationships, and derivative contracts, as well as group taxation principles such as group relief and group capital gains. The course additionally addresses cross-border intra-group financing, tax treaty issues, and the role of offshore finance and international taxation.

By the end of the course, students will be proficient in assessing the tax consequences of corporate financial transactions and applying tax principles to real-world corporate finance scenarios.

20 hours of classes in the Winter Term.

This course has a reading week in Week 6 of Winter Term.

Essay.

• Richard Bramwell, QC; John Lindsay; Alun James; Julian Hickey; Michael Collins, Taxation of Companies and Company Reconstructions (Sweet & Maxwell, looseleaf, 3 volumes)
• Tolley's Yellow Tax Handbook 2024-25 
• Myron S Scholes and others, Taxes & Business Strategy, Global Edition (Pearson Education 2015) 
• Peter Harris, Corporate Tax Law: Structure, Policy and Practice (Cambridge University Press, 2013, second edition, 2024) 
• Peter Holgate, Accounting Principles for Lawyers (Cambridge University Press, 2013) 
• David Southern, Taxation of Loan Relationships and Derivative Contracts (Bloomsbury, 2024) 

Exam (100%), duration: 150 Minutes in the Spring exam period.