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Masters (MSc) in International Taxation – Validation to be finalised (Middlesex University)

The MSc in International Taxation will be offered from the second quarter of 2022.  The full MSc will provide the candidate with the in-depth knowledge and practical experience in International Taxation that will enable them to fulfil a senior position as a transfer pricing specialist.

The MSc is completed over two full academic years and contains the following 3 Stages:

Stage 1, Module 1

Students who have already completed this module in the PG-C are not required to complete it again.

The aim of this module is 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 element: 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. The reorganization of a multinational corporation with foreign subsidiaries in several countries is an example. 

Stage 1, Module 2

Students who have already completed this module in the PG-C are not required to complete it again.

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:

  • 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.
  • 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. 
  • 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).
  • Key principles for International Tax Planning. 
  • 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

Stage 2, Module 1

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.

Stage 2, Module 2

The aim of this module is 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 the contents of a Model Treaty consist of; 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.

Stage 3 – Dissertation

  • The main objective of the dissertation is to apply your knowledge of International Taxation, through research, to explore the unknown and unlock new possibilities within the practice area of International Taxation.
  • The aim of the dissertation is to develop a careful and detailed study of a proposed problem or concern in International Taxation, and implement the knowledge gained from Stages 1 and 2 of the programme in order to sufficiently research, consider and respond to the problem.
  • A further aim is an in-depth analysis of the information learned in order to generate new questions, concepts and understandings within the practice area of International Taxation. 

Who will benefit from this programme?

The structure of the programme is both theory and practice-oriented, and it is designed in a manner to enrich your advisory and consulting skills. International Taxation is an ever-growing and complex field, particularly in an age where governments are striving for deeper collaboration with one another to tighten the tax net.  It is essential that students obtain a thorough understanding of the OECD Income and Capital Model Convention and the UN Double Taxation Model Convention, but also grow a basic understanding of Transfer Pricing.  Students who are able to master this, as well as the additional concepts taught through this programme will firmly place them in a position for a career in International Taxation. 

People who would most benefit from this programme are:

  • CFO’s
  • Financial Directors
  • Financial Managers
  • Accountants
  • Tax Accountants
  • Tax Layers
  • Group Tax Managers
  • Tax Managers
  • Corporate Financial Consultants/ Advisors
  • Entry to mid-level tax employees at MNE’s or Revenue Services
  • Revenue Service Officials
  • In house tax specialists of MNEs; 
  • Head of Tax
  • Group Tax Manager
  • Tax Director
  • Head of Corporate Tax
  • Tax Manager
  • Head of Group Taxation
  • Tax Partner
  • Senior Tax Consultant
  • Partner

 

Next Intake

The next intake will take place after final validation by Middlesex University.  It is anticipated to be in the second quarter of 2022.

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