Applications for the Advanced Certificate in International Taxation (AFRICA) program are now being accepted by IITF.

COURSE DATES & DURATION

This course is a full academic year Post Graduate course.

The course starts in the first week of April – The full curriculum will be sent to you on completion of application.

* Please note that the IITF have the right to change the timing of this course, as long as they remain in line with the requirements of the necessary accreditation authorities.

COURSE FORMAT

  • All notes and lecture material will be made available via the internet;
  • A short assignment must be completed after each section;
  • LIVE lectures will be conducted on the internet via our Online classroom every week;
  • An exam will be written at half way through and at the end of the course;
  • Upon successful completion of this course certification will be issued by Thomas Jefferson School of Law.

CURRICULUM

OVERVIEW

  • INBOUND AND OUTBOUND INVESTMENT
  • REGULATORY ENVIRONMENT
  • INTERNATIONAL DOUBLE TAXATION
  • ROLE OF THE INTERNATIONAL TAX ADVISOR

DOUBLE TAX AGREEMENTS

  • OECD MODEL TAX TREATIES
  • INTERPRETATION OF TREATIES

JURISDICTIONS TO TAX

  • SOURCE, RESIDENCE, TAX TREATY PROVISIONS
  • TERMINATION OF RESIDENCE
  • CITIZENSHIP AND DOMICILE

PERMANENT ESTABLISHMENTS AND BUSINESS PROFITS

  • MEANING OF ENTERPRISE, MEANING OF BUSINESS PROFITS
  • CARRYING ON OF A BUSINESS IN THE SOURCE STATE
  • PERMANENT ESTABLISHMENTS
  • CALCULATION AND ATTRIBUTION OF BUSINESS PROFITS

DTA PROVISIONS – INCOME FROM EMPLOYMENT AND OTHER PROFESSIONAL RELATED INCOME

  • INDEPENDENT PERSONAL SERVICES
  • INCOME FROM EMPLOYMENT
  • DIRECTOR’S FEES, PENSIONS AND ANNUITIES
  • STUDENTS
  • MEMBERS OF DIPLOMATIC MISSIONS AND CONSULAR POSTS

DTA PROVISIONS – COMPANIES AND DIVIDENDS

  • RESIDENT COMPANIES
  • CORPORATE RESTRUCTURING RULES
  • NON-RESIDENT COMPANIES
  • DIVIDENDS UNDER TAX TREATIES

DTA PROVISIONS – IMMOVABLE PROPERTY, CGT AND TAX ON CAPITAL

  • INCOME FROM IMMOVABLE PROPERTY
  • CGT
  • TAXES ON CAPITAL

DTA PROVISIONS – INCOME FROM INTERNATIONAL TRAFFIC AND OTHER INCOME

  • INTERNATIONAL TRAFFICKING
  • OTHER INCOME

CROSS-BORDER FINANCING

  • DEBT V EQUITY
  • HYBRID INSTRUMENTS
  • DERIVATIVES
  • CROSS-BORDER LEASING

INCOME DENOMINATED IN FOREIGN CURRENCY

  • FOREIGN CURRENCY CONVERSION RULES
  • CFC RELATED ISSUES
  • CONVERSION OF FOREIGN TAXES
  • TREATY PROVISIONS

TRUSTS

  • LEGAL NATURE AND DURATION
  • LEGAL FRAMEWORK
  • TYPES
  • BENEFICIARIES AND THEIR RIGHTS
  • FIDUCIARY DUTY
  • INTERNATIONAL ISSUES

INTERMEDIARY HOLDING COMPANIES

  • REASONS FOR ESTABLISHING
  • DOMESTIC ISSUES
  • TREATY ISSUES

HEADQUARTER COMPANIES

UNILATERAL AND TAX TREATY RELIEF

  • TREATY RELIEF

WITHHOLDING TAX

ENFORCEMENT AND COLLECTION OF INTERNATIONAL TAX OBLIGATIONS

  • MAP
  • EXCHANGE OF INFORMATION
  • NON-DISCRIMINATION

TAX AVOIDANCE

  • COMMON LAW REMEDY
  • DOMESTIC LAW
  • TREATY PROVISIONS

CONTROLLED FOREIGN COMPANIES

  • FOREIGN JURISDICTIONS
  • CFCS AND TREATIES

TRANSFER PRICING AND THIN CAPITALIZATION

  • TRANSFER PRICING
  • THIN CAPITALIZATION

EXCHANGE CONTROL

  • EXCHANGE CONTROL PROVISIONS APPLICABLE TO NON-RESIDENTS
  • EXCHANGE CONTROL PROVISIONS RELATED TO NON-RESIDENTS
  • CONTRAVENTIONS AND PENALTIES

THE USE AND ABUSE OF TAX HAVENS

  • REASONS FOR UTILIZING TAX HAVENS
  • DISTINCTIONS BETWEEN TAX HAVENS
  • CONTROVERSY

COURSE COSTS

  • US$ 1,980.00* once off; or
  • Payment terms (4 equal payments) can be arranged – please speak to ;
  • Excludes prescribed books.

SPECIAL ARRANGEMENT: PAY ONLY US$ 1,683.00 (-15% on full price) if full fees are paid within 10 days of application submission.

*All prices are quoted in US$ as the IITF is an international institution and deals with students in over 20 African countries – please convert to your local currency.

PRESCRIBED BOOKS

  • To be confirmed

APPLICATION FORM
Click here for application form.

INQUIRIES

For more information please complete the Inquiry Form below, or contact the student liaison, lesia@iitf.net

LECTURERS

  • Prof A. Venter
  • Dr. Daniel N. Erasmus
  • Karl Muller