International Taxation Postgraduate Diploma

PG-Dip International Taxation – What you will Study

The Postgraduate Diploma, includes Stage 1 (building the foundational knowledge of International Tax) and Stage 2. Stage 1 is dealt with on the PG-Cert page. In Stage 2, students will engage in an in-depth exploration of key international taxation issues, including jurisdictional principles, transfer pricing, anti-avoidance measures, comprehensive treaty analysis, and critical emerging developments such as the BEPS initiative and Pillars One and Two.

Stage 1 & Stage 2

Exit Qualification: PG-Diploma, or progress to Stage 3 for Masters (MSc)

This award consists of 2 Stages. For the Postgraduate Diploma award Stage 1 & Stage 2 must be completed, consisting of 120 credits in total.

Each stage contains two modules:
- Stage 1 – Introduction to International Taxation & Overview of International Tax Concepts, with 30 credits awarded per module.
- Stage 2 (detailed below) – Expanded International Tax Concepts & Specialised Areas, 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 programme work 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 THE PROGRAMME

STAGE 1

Module 1 (Introduction to International Taxation)
Module 2 (Overview of International Tax Concepts)

Click here to view Stage 1

STAGE 2

MODULE 3 – Expanded International Tax Concepts

The student who progresses from Stage 1, now has a basic understanding of the main International Taxation Concepts. The main aim of this module is to expand on the areas of Jurisdiction of Tax, Double Tax and Transfer Pricing. The overall aim includes:

Obtaining an extensive understanding of where and what the tax jurisdiction is for a transaction. This is extremely important because this lays the foundation for fundamentally understanding International Taxation and its various concepts.
The student will explore in-depth how double taxation relief works and is to be applied within these various tax concepts.
Extensive guidance to a student’s understanding of the Arm’s Length Principle, the various Transfer Pricing methods and how the comparability analysis is to be performed.
Broad overview to the following type of Transfer Pricing transactions: Cost Contribution Arrangements, Loans/advances transactions, tangible and intangible transactions and service-related transactions.
Create awareness of the documentation requirements associated with Transfer Pricing and Treaty aspects.

Learning outcomes:

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

Knowledge (understanding)

Fully comprehending Jurisdiction of Tax and its (far racing) consequences.
Critically assess the double taxation relief principles of taxation of parties, the various methods of credits, tax sparing, underlying credits and how this is to be applied in tax calculations.
Critically assess transactions where the Transfer Pricing principles are to be applied.
Appraise the concept of the Arm’s Length Standard and the application of the various TP Methods and be able to perform a high-level Comparability Analysis,
Identify and contrast cost contribution arrangements, loans/advance transactions, and the use of tangible & intangible property from other transactions.
Cite Transfer Pricing transactions appropriately.

Skills (competencies)

Fundamental understanding of tax jurisdiction in order to successfully understand, interpret and apply (most) International Taxation concepts.
Interpret the fundamentals of double taxation relief and the impact on a tax computation taking into account the various types of credits/exemptions/relief which can be provided.
Discuss and critically explain Transfer Pricing principles per the OECD guidelines, to identify transactions that require the application of Transfer Pricing principles relating to the Arm’s Length Standard, the various methods in determining the Arm’s Length Standard and the performing of a comparability analysis.
Distinguish other types of Transfer Pricing transactions: loan/advances, use of tangible and intangible property, Cost Contribution Arrangements.
Illustrate the Transfer Pricing documentation requirements and treaty aspects in Transfer Pricing transactions.

MODULE 4 – Specialised Areas

This module aims to ensure:

A detailed understanding of general Anti-Avoidance principles. Thin Capitalisation and the application of the CFC rules are also explained in greater length. The student is to obtain an acceptable level of knowledge of how CFC principles are to be applied.
The student understands and can demonstrate the legal nature and effect of Tax Treaties.
Understanding what the objectives of Treaties are, the interpretation of Tax Treaties and a summary of the provisions of the OECD and UN Model Treaties.
Comprehension of what the contents of a Model Treaty consist of; and Special Treaty issues are also introduced to the student.
An in-depth look at Emerging issues, including, but not limiting, Base Erosion and Profit Sharing, Hybrid Arrangements, taxation of management, technical and consulting services, the Arbitration principles and the taxation of the Digital Economy.

Learning outcomes:

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

Knowledge (understanding)

Recognise and interpret what Anti-Avoidance measures entail, and specifically how thin capitalisation, and the CFC Rules per International Tax principles are to be applied to assist with the anti-avoidance process.
Evaluate the legal nature and effect of Tax Treaties and how these Treaties are to be interpreted and applied.
Identify the contents of a Model Treaty and which Special Treaty aspects are to be included.
Assess and appraise various emerging issues within the broader International Tax environment, namely: Base Erosion and Profit Sharing, Hybrid Arrangements, taxation of management, technical and consulting services, Arbitration principles and the taxation of the Digital Economy.

Skills (competencies)

Interpret and evaluate when and how to apply anti-avoidance measures to transactions, making use of tax treaties, thin capitalisation and CFC principles.
Interpret and illustrate the correct contents which are to be included in Tax Treaties.
Demonstrate key emerging tax issues and be able to understand the tax impact and application thereof to specific transactions.

ASSESSMENT SCHEME

Stages 1 & 2 (4 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)

Upon successful completion of Stage 2, you will automatically become eligible to progress to Stage 3—the Master’s (MSc) Dissertation.