The PG-Cert (Stage 1) applies international taxation concepts to business, showing how one or multiple countries’ income tax laws affect multinationals. Topics include cross-border trade, manufacturing and resource development, investment by individuals and funds, and expatriate work. Building on Module 1, it surveys residence of individuals and entities, taxation of residents and non-residents, planning principles, and key concepts such as tax jurisdiction, transfer pricing, anti-avoidance, and treaties, developed further in Stage 2.

Duration

7 months, part-time

Credits

60 University Credits

Effort

6–10 hrs/week average*
*Student dependent

Assessment

4x Coursework Assessments,
2x Module Assessments

Format

Online – Recorded lectures, Prescribed Reading, Live Q&As

Award

PG-Certificate, Middlesex
University

PG-Certificate (Stage 1) Overview

Exit Qualification: Postgraduate Certificate, or progress to Stage 2 for Postgraduate Diploma

The Postgraduate Certificate is Stage 1 of the programme and carries 60 credits in total.

  • This stage comprises two modules, Introduction to International Taxation and Overview of International Tax Concepts, with 30 credits each.
  • Teaching focuses on key issues to build a thorough understanding.
  • Students must complete and pass the coursework assessments and the end-of-stage exam to earn the award.
  • Each week features pre-recorded lectures with prescribed reading and, where relevant, additional sources. Directed reading covers case law, legislation, books, articles, and academic or professional journals.
  • Learning is reinforced with case studies, practical examples, and resources that test thinking in real contexts. Discussion forums, quizzes, polls, and other activities support the learning outcomes.
  • Each main topic concludes with a live online tutorial led by lecturers. Tutorials are interactive, offering time for questions and for examining issues from different perspectives.

This extensive module explores the concepts of International Taxation and its application in business. It encompasses a wide range of tax issues influenced by a single, or multiple countries’ income tax laws. 

The module provides an understanding of how international tax impacts companies with multinational operations and highlights issues raised by present-day international tax practices. 

Examples covered include cross-border trade in goods and services, cross-border manufacturing, production, and resource development by a multinational enterprise, cross-border investment by individuals or investment funds, and individuals working outside the country where they usually reside.

Learning Outcomes

On successfully completing this module, the student will be able to:

  • Compare and contrast International Tax Law within the broader concept of Tax Law.
  • Apply International Taxation principles in actual business transactions.
  • Analyse the Model Tax Conventions used for International Tax.
  • Interpret other International Law, which also links to International Tax Law.
  1. Critically assess and identify how international tax impacts companies with multinational operations.
  2. Critically examine the ethical and moral issues raised by present-day international taxation practices.
  3. Assess and apply complex legal concepts and key case law related to International Taxation.
  4. Analyse and synthesise complex concepts relating to International Taxation, beyond just income tax.
  5. Justify the goals of international taxation.
  6. Evaluate the role of the tax advisor with respect to international taxation transactions.
  1. Cogently present the concept of International Tax, and understand why International Tax exists and how it links to other forms of Taxation.
  2. Compare and contrast International Tax Law within the broader concept of Tax Law.
  3. Interpret other International Law, which also links to International Tax Law.
  4. Apply International Taxation principles in actual business transactions.
  5. Analyse the Model Tax Conventions used for International Tax.

This module gives a broad, practical overview of international taxation and the habits needed to analyse real cases. It starts with residence for individuals and legal entities, showing how it is determined, why dual residence occurs, and how treaty tie-breakers and competent authority resolve conflicts. From there, it maps the consequences once residence is fixed, including liability on worldwide income, foreign tax relief, and core reporting obligations. 

The module then turns to source rules for employment and services income, business profits, and investment income, explaining how domestic law and treaties allocate taxing rights, prevent double taxation, and manage timing and character mismatches. 

You will work through how residents and non-residents are taxed on local and worldwide income, and where permanent establishment, place of effective management, and withholding regimes change outcomes. Alongside doctrine, you will develop practical tax-planning principles focused on lawful structuring, substance, documentation, and dispute readiness. 

Case studies highlight risk points such as hybrid arrangements, treaty shopping, and remuneration of cross-border functions. The module also builds a working foundation in the core concepts that underpin the field, namely jurisdiction of tax, transfer pricing, anti-avoidance, and treaties. 

You will learn to identify the relevant provision, interpret it using accepted methods, and apply it to facts with clear reasoning. These areas are introduced here to give you a coherent model of how the system fits together, then explored in depth in Stage 2.

Learning Outcomes

On successfully completing this module, the student will be able to:

  • Examine and determine International Tax principles for non-residents (individuals and legal entities) to their various types of income, including double taxation rules for such residents.
  • Interpret and broadly evaluate anti-avoidance measures.
  • Recognise Tax Treaties with the understanding of their implementation.
  • Identify opportunities for International Tax Planning.
  1. Broadly analyse the concept of residence for individuals and legal entities with specific reference to the source rules for international taxation, including an interpretation of the treaty issues relating to this residence principle.
  2. Identify and determine the source rules to employment, personal services income and business income, including investment income. 
  3. Explicate the taxation of residents, ranging from the tax policy aspects thereof to consequences of residency and its impact on the worldwide income of a resident and temporary resident.
  4. Broadly understand the double taxation relief principles of taxation.
  5. Evaluate the taxation of non-residents, ranging from the tax policy aspects thereof to the source rules, double taxation principles and the taxation of the various types of income of non-residents.
  6. Broadly assess transactions where the Transfer Pricing principles are to be applied.
  7. Recognise and interpret what Anti-Avoidance measures entail.
  8. Identify the contents of a Model Treaty and which Special Treaty aspects are to be included.
  9. Critically assess methods for effective International Tax Planning.
  1. Differentiate and compare resident and non-resident taxpayers in relation to their residency status and the consequences thereof.
  2. Analyse and apply International Tax principles for residents (individuals and legal entities) to their various types of income. 
  3. A broad overview of the fundamentals of double taxation.
  4. Examine and determine International Tax principles for non-residents (individuals and legal entities) to their various types of income, including double taxation rules for such residents.
  5. Discuss and broadly explain Transfer Pricing principles per the OECD guidelines.
  6.  Interpret and broadly evaluate anti-avoidance measures.
  7. Recognising Tax Treaties and how they are implemented and interpreted.
  8. Understand and identify opportunities for International Tax Planning.

The assessment scheme consists of the following, (per module):

  • Coursework Assessment 1 (20 Marks)
  • Coursework Assessment 2 (20 marks)
  • Final Assignment (60 Marks)
  • Total – 100 Marks

To qualify for the Postgraduate Certificate (or progress to Stage 2) the candidate must complete both modules.

Download Course Brochure

PG-Cert | PG-Dip | MSc

Course Brochure PG-InTax

We would like to keep in touch to provide you with relevant guidance, advice, tips and updates so you can make the right choice for you, based on the information you have provided us. By submitting your details, you are agreeing to the Academy of Tax Law's privacy policy.


Students rate this programme 97.2%

Shopping Cart
Scroll to Top

Compare Programmes

Choose the track that fits your practice focus. All programmes are practitioner-taught, cohort-based, and validated by Middlesex University.

Dimension Transfer Pricing International Taxation South African Tax Law
Jurisdictional audience Global audience, covers all jurisdictions Global audience, covers all jurisdictions South Africa specific, relevant to SADC region
Ideal for TP managers, advisors, in-house tax teams, analysts moving into TP Advisors and managers dealing with cross-border rules, treaties, planning Practitioners working with the SA Income Tax Act, cases, compliance
Core focus Methods, comparables, DEMPE, documentation, audits, dispute defence Treaties, source vs residence, anti-avoidance, PE, relief from double tax Statutory interpretation, case law, assessments, objections, local practice
Primary tools OECD TP Guidelines, UN Manual, BEPS Actions 8–10, 13, case law OECD and UN Models, MLI, BEPS 1.0 and 2.0, domestic rules, cases Income Tax Act, SARS practice notes, Tax Administration Act, SA cases
Assessment style Case-based assignments, file reviews, short written defences Problem questions, treaty interpretation, position papers Problem questions, statutory analysis, case commentary
Typical outcomes Build defensible TP files and strategies, improve audit readiness Design cross-border structures within rules, mitigate double tax Apply SA tax law accurately, manage reviews and disputes
Entry point Start with PG Certificate, progress to PG Diploma, then MSc, or enter later with suitable experience or credits.

Awards Ladder

Award Best for What you achieve Assessment highlights
PG Certificate Foundation to intermediate upskilling Core concepts, frameworks, and applied techniques Short case write ups, timed responses, applied tasks
PG Diploma Expanding technical depth and application Advanced analysis, risk management, documentation quality Integrated case assignments, policy memos, oral defence
MSc Leaders and specialists building authority Capstone project and research backed practice outcomes Research project, viva or presentation, publishable summary

IFF Certificate Courses

Practical, practitioner-led certificates designed for immediate on-the-job application. Each course can stand alone or act as a pathway into our postgraduate tracks.

Dimension Conducting a Transfer Pricing Trial Effectively Managing Tax Teams Indirect Taxation Tax Risk Management
Jurisdictional audience Global audience Global audience Global audience, with local adaptation Global audience
Ideal for In-house tax, TP managers, litigators, advisors preparing for audits, ADR, trial Heads of tax, managers, team leads, controllers, emerging leaders VAT, GST, customs, finance managers, AP, AR, compliance specialists Tax managers, risk officers, controllers, advisors building governance
Core focus Case theory, evidence files, expert reports, witness prep, courtroom strategy Operating models, KPIs, workflows, stakeholder management, coaching VAT design, place of supply, input credits, exemptions, WHT interactions Risk identification, controls, documentation, audit readiness, dispute playbooks
Delivery mode Online, live sessions plus guided self-study Online, live sessions plus guided self-study Online, live sessions plus guided self-study Online, live sessions plus guided self-study
Duration 16 weeks, part-time 16 weeks, part-time 16 weeks, part-time 16 weeks, part-time
Outcomes Confident litigation preparation and defence for TP disputes Stronger execution, clear roles, measurable team performance Reduced VAT errors, better cash flow, fewer surprises at audit Structured governance, fewer findings, faster dispute resolution
Prerequisites TP fundamentals recommended Supervisory experience helpful Basic VAT knowledge helpful General tax experience helpful
Pathway Progress to PG Certificate in Transfer Pricing Progress to Mechanics of Leading Tax Teams, PG Certificate (leadership) Progress to PG programmes, International Tax or SA Tax Law Progress to PG Certificate in International Taxation or Transfer Pricing
Assessment End of module progress assessment

5000-word assignment if PG-Cert option elected
End of module progress assessment

5000-word assignment if PG-Cert option elected
End of module progress assessment

5000-word assignment if PG-Cert option elected
End of module progress assessment

5000-word assignment if PG-Cert option elected