Enrollments are now open for the next Intake
I/I/T/F has been offering the PG-D in International Taxation in its current form since 2020, however, it has been run as a full PG-D since 2011.
The PG-D is the pre-emptive programme for any professional wanting to fulfil a full-time career in the field of international taxation.
The central aim of this programme, which consists of 2 stages, is to provide a comprehensive grounding in all aspects of International Taxation. Stages 1 and 2 contain 2 modules each, which address the important issues within the sector, drawing out key points to ensure you gain a thorough understanding of the topics before completing the final exam.
With this programme candidates will:
- Expand your skills and gain knowledge in an area of considerable commercial interest which will enhance your employability potential in this area
- Develop an in-depth and practical understanding of Cross Border taxation
- Examine the latest policy developments and tax treatment of complex cross-border transactions that organisations need to deal with in an increasingly demanding regulatory environment
- Undertake a flexible, alternative study solution to a traditional on-campus programme, tailor-made for working professionals and studied 100% ONLINE
- Improve your career prospects by gaining a high-level qualification without compromising your work commitments and gain the professional skills and practical experience that businesses are looking for today
The PG-D is competed over a full academic year and contains the following 2 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 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.
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 strive for deeper collaboration 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.
Progression Path
By successfully completing all the assessments in modules 1 to 4 the candidate has the to opportunity complete Stage 3 to obtain a Masters (MSc) in International Taxation.
Next Intake
PG-D Intakes run in March and July of each year.
