Professional Certificate in International Taxation and Transfer Pricing


Start date: Jan 25, 2023

Payment options per semester:

Payment option 1: Once-off payment:

Full course fee: R25 950.00

First semester fee: R12 975.00

Payment option 2: Debit order

Application fee: R450.00

First payment upon approval: R5 000.00

Monthly fee: R1 850.00 per month, five instalments per semester


Lecturer: Marcus Stelloh
Director & Head of Transfer Pricing: BDO
Lecturer: Martie Foster
CA(SA), HDip (Tax Law) [UJ], MCom in Taxation (International Tax) [UCT]

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.

Please see full course payment breakdown below.

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.

Accreditation

This course is presented as a SLP by The Tax Faculty (TTF) and approved by the Chartered Institute of Taxation as a preparation course for the ADIT examination for Principles of International Taxation. TTF is recognised as a continuous professional development (CPD) provider by controlling bodies accredited in terms of the Tax Administration Act, 2011 (Act No 28 of 2011), and holds accreditation with the Quality Council for Trades and Occupations as a skills development partner (SDP) under the Skills Development Act, 1998 (Act No 97 of 1998).


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, learners may elect to register for examinations via the Advanced Diploma in International Tax, offered in partnership with the Chartered Institute of Taxation.

In addition, this just-in-time learning programme also qualifies for verifiable CPD.


Student support and online campus

The academic and practical skills component of the qualification is delivered on The Tax Faculty's online iLearnTax Campus.

This will be your virtual campus for the duration of the programme. The course is presented as micro-learning videos, study guides, practice quizzes, discussion forums, practical case studies, assignment briefs and guided presentations on how to master case studies and assignments. Academic lecturers are available on the Q&A portal as they would be in a classroom.

At the beginning of each semester, you'll be presented with the course content plan, a study plan and important assignment dates which are set out at manageable deadlines. This will help you study at your own pace.

In addition, you will be allocated a course consultant who will help you navigate the online campus, support you with your weekly participation and deadlines, and will be able to answer any administrative queries you may have.


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

For courses with a 12-month or longer rollout, the following will apply:

  • If the cancellation is requested more than two weeks prior to the course start date, no cancellation fee will be applicable.
  • If the cancellation occurs less than two weeks prior to the course start date, a 25% cancellation fee will be applicable on the full course fee.
  • Should a cancellation be received within six weeks after the course start date, the student will still be liable for 50% of the full course fee.
  • Should the cancellation be received after six weeks of the course start date, the student will be liable for the full course fee.
  • 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.
  • Students who have failed to successfully complete the course, and wishing to repeat will be charged the full course fee to repeat.

Why wait?

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