International Taxation Postgraduate Certificate

PG-Cert International Taxation – What you will Study

International Taxation encompasses a wide range of tax issues influenced by a single, or multiple countries’ income tax laws. The qualification provides an understanding of how international tax impacts companies with multinational operations and highlights issues raised by present-day international tax practices.

STAGE 1

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

This Postgraduate Certificate award is the stage 1 of this programme and consists of 60 credits in total.

  • This stage will contain two modules (Introduction to International Taxation & Overview of International Tax Concepts), with 30 credits awarded per module.
  • The learning will address important issues within the sector, drawing on key points, to ensure you gain a thorough understanding of the topics.
  • Students must complete and successfully pass the assigned coursework assessments and the final exam at the end of each stage to claim their award.
  • Pre-recorded academic lectures will be released each week, accompanied with the prescribed reading, any additional reading and/or research, as required. Directed reading will relate to provided case law, and will also include reading from legislation, books, articles, academic and professional journals.
  • The learning from the lectures will be emphasised with an array of case studies, practice examples and resources, to challenge thinking in a practical context. Engaging activities on the discussion forum, the use of quizzes, polls and other forum built-in activity will further validate the learning objectives.
  • Each main topic will end with a live-online tutorial, conducted by the lecturers. The tutorials are designed to be interactive, providing students with the opportunity to ask questions and to consider issues from different perspectives.

AIMS OF STAGE 1

MODULE 1 – Introduction to International Tax

This module aims to explore the concept of International Taxation and its application in business.

It encompasses a wide range of tax issues arising under a country’s income tax laws that include some foreign elements: for example, 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. These activities usually present international tax issues under the tax laws of at least two countries. Some international tax issues arise out of extremely complex situations. An example is the reorganisation of a multinational corporation with foreign subsidiaries in several countries.


Learning outcomes:

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

Knowledge (understanding)

  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.

Skills (competencies)

  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.

MODULE 2 – Overview of International Tax Concepts

The main aim of this module is to introduce the student to a broad overview of the most important areas in International Taxation.  This includes:

  1. Understanding that residence relates to individuals and legal entities and once confirmed, there are various consequences relating to the tax thereof. Furthermore, it is necessary to understand the treaty aspects relating to the Residence.
  2. The Source of a transaction is also discussed in terms of Employment and Services Income as well as Business Income, including Investment Income. This is important to ensure the student understands how these various types of income are to be taxed based upon International Tax Principles. 
  3. Providing the student with a thorough understanding of how residents and non-residents are to be taxed on their income (local and foreign/worldwide income).
  4. Key principles for International Tax Planning. 
  5. Broad-based introduction and the ability for the student to identify and interpret the following International Taxation concepts.  Each of these concepts will be expanded on in Stage 2 (MSc/ PG-D route):
    • Jurisdiction of Tax
    • Transfer Pricing
    • Anti-Avoidance
    • Treaties

Learning outcomes:

On successful completion of this module, the student will be able to:

Knowledge (understanding)

  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.

Skills (competencies)

  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.

ASSESSMENT SCHEME

Stage 1 – PG-Cert (2 Modules)

The assessment scheme for each module shall consist of the following:

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

Stage 1 leads directly into Stage 2, The Postgraduate Diploma in International Taxation.