Professional Certificate in Principles of International Taxation

Date: Jan 25, 2023 - Jun 30, 2023

Application fee: R1,950.00

Once-off: R16,950.00

Lecturer: Marcus Stelloh (Partner: BDO)

The purpose of this short learning programme (SLP) is to equip learners with the adequate skills to understand the intricacies of the international tax laws. It will develop learners’ understanding of double taxation conventions, transfer pricing, thin capitalisation rules and international tax avoidance.

Please see full course payment breakdown below.

Course overview

The course prepares learners to successfully complete the first compulsory module of the Advanced Diploma in International Tax (ADIT), offered in partnership with the Chartered Institute of Taxation.

The SLP is divided into five parts:

  1. Basic principles of international tax law.
  2. Double taxation conventions (DTCs), focusing on the Organisation for Economic Co-operation and Development (OECD) model tax convention.
  3. Transfer pricing and thin capitalisation rules.
  4. International tax avoidance.
  5. Miscellaneous topics.

What you will learn

The course will cover the following concepts:

Basic principles of internal tax law
  • Jurisdiction to tax, including limits to tax jurisdiction arising from public international law, and cross- border enforcement of taxes.
  • Taxes and tax systems.
  • State practice in exercising tax jurisdiction.
  • Causes of international double taxation.
  • Methods of relief from international double taxation.
  • Private international law and tax.
  • The history of international tax law.
  • European Union law and international tax.
  • Tax and international human rights instruments.
  • State responsibility in international tax – the development of the concept of harmful tax competition.

Double taxation conventions (DTCs) focussing on the current version of the OECD model tax convention (MTC)

Learners are expected to understand the operation of the provisions of the OECD MTC, show awareness of the major points in the commentary to the relevant article of the OECD MTC and be aware of key reports of the OECD Committee on Fiscal Affairs and major international cases on the topic. This includes:

  • Types of DTCs (limited, multilateral etc.) and negotiation of DTCs.
  • DTCs and domestic law.
  • Format and structure of a DTC.
  • Approach to the application of a DTC: applying a DTC to a concrete scenario.
  • Interpretation of DTCs.
  • Provisions relating to the scope of a DTC: Articles – 1, 2, 29, 30, 31 and 32.
  • Key definitional provisions.
  • DTC provisions relating to businesses.
  • DTC provisions relating to individuals.
  • DTC provisions relating to investment income and gains.
  • Relevance of the “other income” – Article 21, OECD MTC.
  • Limitation of benefit provisions.
  • Methods of elimination of double taxation – Articles 23A and 23B, OECD MTC.
  • The impact of the non-discrimination article – Article 24, OECD MTC.
  • The resolution of disputes under DTCs.
  • The application of DTCs to electronic commerce.
  • The digital economy.
Transfer pricing and thin capitalisation rules
  • Various approaches to the determination of profits of branches and associated enterprises.
  • State practice with respect to transfer pricing.
  • Transfer pricing and DTCs – Article 9, OECD MTC.
  • Advanced pricing agreements.
  • The OECD Transfer Pricing Guidelines 2017.
  • Transfer pricing and BEPS.
  • Transfer pricing and developing countries.
  • State practice with respect to thin capitalization.
  • Thin capitalization legislation and DTCs.
International tax avoidance
  • Tax havens.
  • Domestic law approaches to international tax avoidance.
  • Money-laundering legislation and international tax avoidance.
  • Cooperation between revenue authorities.
  • Conventions for administrative assistance in tax administration.
  • Base erosion and profit sharing (BEPS).

Miscellaneous topics

  • Indirect taxes and international taxation.
  • Cross-border mergers.
  • Estate and gift taxation and international issues.

Admission requirements

Open to individuals currently working within transfer pricing or for experienced tax practitioners/accountants wanting to specialise in transfer pricing. An NQF 7 qualification in taxation, law, or accounting is recommended.

Mode of delivery

The course is delivered via The Tax Faculty's virtual campus via an interactive online platform. Learning resources include study guides, prescribed reading, numerous short video lectures, short self-assessments, and longer simulated scenarios.

Course duration

Six months.


This course is presented as a SLP by The Tax Faculty (TTF). TTF is accredited as a continuous professional development (CPD) provider by the South African Institute of Taxation (SAIT), a South African Revenue Services Recognised Controlling Body (RCB) under the Tax Administration Act, 2011 (Act No 28 of 2011).

TTF is registered as a skills development partner (SDP) under the Skills Development Act, 1998 (Act No 97 of 1998) by the Quality Council for Trades and Occupations (QCTO).

Assessment and award of certificate

Learners are assessed via a number of formative and summative assessments. Successful learners will receive a SLP certificate issued by The Tax Faculty. This SLP certificate is non-credit bearing, however, successful learners articulating into the Occupational Certificate: Tax Technician (NQF 6) programme, will obtain recognition for prior learning (RPL) towards the NQF 6 qualification. In addition, this just-in-time learning programme also qualifies for verifiable CPD.

Learners may elect to register for this standalone examination via the Advanced Diploma in International Tax, offered in partnership with the Chartered Institute of Taxation.

Flexible payment options

Payment option 1: Once-off payment

R16 950.00 (incl. VAT).

Payment option 2: Debit order

Application fee (non-refundable): R1 950.00 (incl. VAT).

Six installments: R2 750.00 per month (incl. VAT).
Total: R18 450.00 (incl. VAT).

This fee excludes any external exams via SAIT or ADIT.

* First debit order will be collected on course start date. Remaining debit orders will be collected on the first 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.


For all short learning programmes (SLPs) with a seven-month or less rollout period, the following will apply:

  • If the cancellation is requested more than 10 working days prior to the course start date, no cancellation fee will be applicable.
  • If the cancellation occurs less than 10 working days prior to the course start date, a 100% cancellation fee will be applicable.
  • Students who register for a course and fail to attend will be held liable for the full course fee.
  • The course application fee is non-refundable.
  • The Tax Faculty’s liability in the case of a course being cancelled will be limited to a refund of the course fee.
  • Students who have failed to successfully complete the course, and wishing to repeat will be charged the full course fee to repeat.

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