Professional Certificate in International Taxation and Transfer Pricing

Overview

Growing international trade and commerce have resulted in international tax both for individuals and corporates and in particular transfer pricing considerations for multinational corporates. This has resulted in cooperation and collaboration with global revenue authorities.

This course combines the Professional Certificate in Principles of International Taxation and the Professional Certificate in Transfer Pricing. It provides students with the required breadth of knowledge, skills and understanding of international tax principles and practices and the main aspects of transfer pricing.

This professional certificate is aimed at tax practitioners who are no longer limited to domestic tax issues and wish to be able to manage and advise on cross-border transactions effectively. 

Mode of delivery

Online learning with flexible weekly study plans.

Effort and duration

Duration: 12 months.

Weekly effort: Four to six hours a week.

What you will learn in this course

The course is divided into two semesters and covers the following modules and topics.

Semester 1: Principles of international tax

• Basic principles of international tax law and principles.
• Double taxation conventions (DTCs), focusing on the Organisation for Economic Co-operation and Development (OECD) model tax convention.
• Transfer pricing and thin capitalisation rules.
• International tax avoidance, including South African anti-avoidance legislation and cases, money laundering and tax havens.
• Miscellaneous topics (indirect taxes, cross-border mergers, and estate duty and donations tax in the context of international tax).

Semester 2: Transfer pricing

• Transfer pricing introduction.
• Arm's length principle.
• Functional analysis.
• Transfer pricing methods.
• Fundamental sources.
• Comparability.
• Specific transactions.
• Permanent establishment.
• Compliance issues and required documentation: ITR14.
• Avoiding double taxation.
• Dispute resolution.

The curriculum detail matches the syllabus of the Advanced Diploma in International Tax (ADIT) offered by the Chartered Institute of Taxation (CIOT) in the UK and prepares learners to successfully complete the first compulsory module of the ADIT and the transfer pricing module.

This course is for you if:

• You are a tax practitioner with domestic tax knowledge seeking a comprehensive and practical understanding of international tax.
• You are an in-house tax practitioner of an enterprise and need to build your confidence, skills, and competencies to identify and apply international tax principles in your environment.
• You are a finance professional working with multinational corporations.
• You are a tax advisor/lawyer seeking to stay abreast of the ever-changing world of international taxation and transfer pricing.

Admission requirements

Open to individuals currently working within taxation, finance, or tax law. An NQF 6 qualification in taxation, law or accounting is recommended.

Outcomes

After successful completion of this programme, you should be able to:

• Determine whether a taxpayer is a SA tax resident or not, considering all local residency rules and international agreements or considerations.
• Assess the tax implications of a taxpayer based on their resident status as well as double tax agreements.
• Identify cross-border transactions as well as the related tax effects after taking any double tax agreements into account.
• Provide tax advice related to a taxpayer’s residency, double tax agreements as well as cross-border transactions.
• Evaluate the effect of transfer pricing on various international transactions.
• Differentiate between tax planning, tax avoidance and tax evasion on an international tax level.
• Identify and apply local and international anti-tax avoidance measures.
• Action transfer pricing compliance of significant complexity.
• Provide advice related to transfer pricing tax risks, processes, and transactions.
• Initiate and manage controversy and dispute resolution in relation to transfer pricing.

Flexible payment options

Payment option 1: Once-off payment 

Once-off payment: R25 950.00.

Alternatively, two semester payments: R12 975.00 per semester (to be paid on or before semester start date).

Application fee (non-refundable, immediate payment upon registration): R450.00. This amount is included in the once-off total and will not be charged additionally.

Payment option 2: Debit order

Once-off application fee (non-refundable, immediate payment upon registration): R450.00 

• Start of first semester (to be paid before or on semester start date): R5 000.00. First semester remaining debit orders, five instalments: R1 850.00 per month.
• Start of second semester (to be paid before or on semester start date): R5 000.00. Second semester remaining debit orders, five instalments: R1 850.00 per month.
• Please note semester invoicing will be processed every six (6) months.

Total for debit order option: R28 950.00.

* First debit order will be collected from the second month of semester start date. Remaining debit orders will be collected on the first working day of each month.

Payments and cancellations

• All required minimum payments must be made by direct EFT or by credit card before the commencement of a course. The once-off payment is required to be paid before the course start date, as well as the application fee of learners on a debit order plan (the first debit order is also required on the start date of the course).
• Kindly note that should debit order payment terms not be adhered to; legal action will be taken and access to the online learning platform suspended.
• Proof of payment may also be requested before access to the iLearn platform will be communicated, should your payment not reflect on The Tax Faculty’s bank account.
• Only written notice of cancellation will be accepted.

Conditions

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