Professional Certificate in Transfer Pricing and International Tax

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 (Partner: BDO)

International tax and transfer pricing is a complex speciality that represents a unique blend of tax law, accounting, business practice and economics and remains a top priority for revenue authorities globally, with a growing emphasis on audits and disputes.

Please see full course payment breakdown below.

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, transfer pricing rules and methods, compliance issues and dispute resolution within a South African context.

Course overview

The course will equip learners to apply the principles of international tax law and the fundamentals of transfer pricing. Learners will be able to complete complex transfer pricing calculations and disclosure within ITR14’s and will be able to respond to disputes and manage resolutions within transfer pricing and international tax.

The SLP is delivered across two semesters:

Semester 1: Focus on international tax

  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.
Semester 2: Transfer pricing specialism
  1. Fundamental sources.
  2. The arm’s length principle.
  3. Functional analysis.
  4. Transfer pricing methods.
  5. Comparability.
  6. Specific transactions.
  7. Permanent establishments.
  8. Compliance issues and required documentation.
  9. Application within the ITR14.
  10. Avoiding double taxation.
  11. Dispute resolution.

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

12 months.

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.


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, conducted via The Tax Faculty’s online platform. Successful learners will receive a SLP certificate issued by The Tax Faculty and in an effort to maintain your professional status and keep your expert knowledge up to date, you will earn relevant CPD hours upon course completion (pending approval of your relevant professional industry body).
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, or may elect to write the SAIT Transfer Pricing Compliance and Advisory exams. The costs for these examinations and related memberships are excluded from the advertised fees.

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.

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.


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.

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