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International Tax Programmes

  • The Tax Knowledge Base
  • International Tax Programmes

INTS1001 - WEEKS 1 & 2: Introduction to International Tax (14)

  • Common Law vs Civil Law: Key Differences in International Taxation Explained
  • Navigating International Tax Without a Double Tax Treaty: FATCA, BEPS, and Transfer Pricing
  • How Brexit Impacted UK-EU Tax and Legal Relations: VAT, Customs, and Directives
  • UN Model vs OECD Model Treaty: Key Differences in Taxation for Developing Countries
  • BEPS 2.0 Developments: Impact on International Tax Trends | Pillar One & Pillar Two Explained
  • Can you give an indication of how the MAP processes work?
View all 14 articles

INTS1002 - Week 17: Introduction to Anti-Avoidance (1)

  • What is the consensus in anti-avoidance legislation between countries within the EU, such as low-tax countries like Bulgaria?
View 1 article

INTS1002 - Week 18: Treaties (4)

  • What happens when the tie-breaker rules do not work, and there is a dispute?
  • Please give examples for Notified Jurisdiction Areas (NJA)? What happens if you have to trade within such jurisdictions?
  • How are inter-company activities treated within NJA (Tax Haven) or OECD grey-listing?
  • Are the intercompany activities taken into consideration in relation to economic substance regulation? Are they counted as a part of the necessary volume of activity and employment?
View all 4 articles

INTS2001 - WEEKS 23 & 24: Jurisdiction of Tax Extended (4)

  • DTAA Article 13(1): Capital Gains Tax on Sale of Property-Rich Holding Company
  • How is the tax jurisdiction handled in the case of digital nomads who have not stayed in a dwelling for more than 183 days?
  • In the case of individuals, how is the jurisdiction of tax handled within the EU when the border can be crossed at any time ?
  • In the case of businesses, are there instances where both place of management and place of incorporation tests fail?
View all 4 articles

INTS2001 - WEEKS 25 & 26: Double Tax/ Foreign Tax Relief (2)

  • Can you please give examples where treaty interpretation differs in cases of double taxation and double non-taxation?
  • How are foreign tax credits treated in cases of significant differences in tax rates?
View all 2 articles

INTS2001 - WEEKS 28 - 30: Transfer Pricing Extended (7)

  • I heard that, due to the recent pandemic, comparables from earlier years (before 2020) are not advisable to use. Is there more reliable data now since we are 4 years down the line?
  • What is the solution for companies that do not have access to expensive databases or consulting?
  • I understand that there is no list of adjustments that the companies can use. However, what are the typical adjustments that draw the attention of the tax authorities?
  • Does ignoring indirect taxes in TP, like VAT or WHT, risk double/triple taxation for cost-plus firms?
  • Is analyzing related party transactions as a whole better than isolating elements for arm's length pricing?
  • Canada v. GlaxoSmithKline: Resale Price vs. CUP Method—Which Was Right for Transfer Pricing?
View all 7 articles

INTS2001 - WEEKS 37 - 39: Treaties Extended (3)

  • Treaties take a long time to renegotiate or cancel. How does this work in cases of conflict between countries and in cases of sanctions being imposed?
  • If a country is part of the European Union BUT not a member of the OECD - does this affect any treaties being entered into?
  • Did Brexit affect the UK's treaties network?
View all 3 articles
  • INTS1001 - WEEKS 1 & 2: Introduction to International Tax
    • Common Law vs Civil Law: Key Differences in International Taxation Explained
    • Navigating International Tax Without a Double Tax Treaty: FATCA, BEPS, and Transfer Pricing
    • How Brexit Impacted UK-EU Tax and Legal Relations: VAT, Customs, and Directives
    • UN Model vs OECD Model Treaty: Key Differences in Taxation for Developing Countries
    • BEPS 2.0 Developments: Impact on International Tax Trends | Pillar One & Pillar Two Explained
    • Can you give an indication of how the MAP processes work?
    • Avoiding Double Taxation on Cross-Border Advisory Fees - An African Example
    • Why is Relinquishing Tax Residency More Scrutinised Than Acquiring It?
    • How does the 183-Day Rule Impact Tax Residency and When It Can Be Nullified?
    • How are source rules that consider income from where business is carried on too vague for guidance?
    • Is double non-taxation a BEPS concern, and can a multilateral instrument prevent it?
    • Can you give examples where domestic tax rules override the UN and OECD Model Treaties?
    • Can a credit be applied if US group companies are treated as disregarded entities with a tick exercise?
    • How can one stay updated with evolving local and international tax changes and react promptly?
  • INTS1002 - Week 17: Introduction to Anti-Avoidance
    • What is the consensus in anti-avoidance legislation between countries within the EU, such as low-tax countries like Bulgaria?
  • INTS1002 - Week 18: Treaties
    • What happens when the tie-breaker rules do not work, and there is a dispute?
    • Please give examples for Notified Jurisdiction Areas (NJA)? What happens if you have to trade within such jurisdictions?
    • How are inter-company activities treated within NJA (Tax Haven) or OECD grey-listing?
    • Are the intercompany activities taken into consideration in relation to economic substance regulation? Are they counted as a part of the necessary volume of activity and employment?
  • INTS2001 - WEEKS 23 & 24: Jurisdiction of Tax Extended
    • DTAA Article 13(1): Capital Gains Tax on Sale of Property-Rich Holding Company
    • How is the tax jurisdiction handled in the case of digital nomads who have not stayed in a dwelling for more than 183 days?
    • In the case of individuals, how is the jurisdiction of tax handled within the EU when the border can be crossed at any time ?
    • In the case of businesses, are there instances where both place of management and place of incorporation tests fail?
  • INTS2001 - WEEKS 25 & 26: Double Tax/ Foreign Tax Relief
    • Can you please give examples where treaty interpretation differs in cases of double taxation and double non-taxation?
    • How are foreign tax credits treated in cases of significant differences in tax rates?
  • INTS2001 - WEEKS 28 - 30: Transfer Pricing Extended
    • I heard that, due to the recent pandemic, comparables from earlier years (before 2020) are not advisable to use. Is there more reliable data now since we are 4 years down the line?
    • What is the solution for companies that do not have access to expensive databases or consulting?
    • I understand that there is no list of adjustments that the companies can use. However, what are the typical adjustments that draw the attention of the tax authorities?
    • Does ignoring indirect taxes in TP, like VAT or WHT, risk double/triple taxation for cost-plus firms?
    • Is analyzing related party transactions as a whole better than isolating elements for arm's length pricing?
    • Canada v. GlaxoSmithKline: Resale Price vs. CUP Method—Which Was Right for Transfer Pricing?
    • Which transfer pricing method suits the diamond industry, given the difficulty in accessing reliable data?
  • INTS2001 - WEEKS 37 - 39: Treaties Extended
    • Treaties take a long time to renegotiate or cancel. How does this work in cases of conflict between countries and in cases of sanctions being imposed?
    • If a country is part of the European Union BUT not a member of the OECD - does this affect any treaties being entered into?
    • Did Brexit affect the UK's treaties network?
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Compare Programmes

Choose the track that fits your practice focus. All programmes are practitioner-taught, cohort-based, and validated by Middlesex University.

Dimension Transfer Pricing International Taxation South African Tax Law
Jurisdictional audience Global audience, covers all jurisdictions Global audience, covers all jurisdictions South Africa specific, relevant to SADC region
Ideal for TP managers, advisors, in-house tax teams, analysts moving into TP Advisors and managers dealing with cross-border rules, treaties, planning Practitioners working with the SA Income Tax Act, cases, compliance
Core focus Methods, comparables, DEMPE, documentation, audits, dispute defence Treaties, source vs residence, anti-avoidance, PE, relief from double tax Statutory interpretation, case law, assessments, objections, local practice
Primary tools OECD TP Guidelines, UN Manual, BEPS Actions 8–10, 13, case law OECD and UN Models, MLI, BEPS 1.0 and 2.0, domestic rules, cases Income Tax Act, SARS practice notes, Tax Administration Act, SA cases
Assessment style Case-based assignments, file reviews, short written defences Problem questions, treaty interpretation, position papers Problem questions, statutory analysis, case commentary
Typical outcomes Build defensible TP files and strategies, improve audit readiness Design cross-border structures within rules, mitigate double tax Apply SA tax law accurately, manage reviews and disputes
Entry point Start with PG Certificate, progress to PG Diploma, then MSc, or enter later with suitable experience or credits.

Awards Ladder

Award Best for What you achieve Assessment highlights
PG Certificate Foundation to intermediate upskilling Core concepts, frameworks, and applied techniques Short case write ups, timed responses, applied tasks
PG Diploma Expanding technical depth and application Advanced analysis, risk management, documentation quality Integrated case assignments, policy memos, oral defence
MSc Leaders and specialists building authority Capstone project and research backed practice outcomes Research project, viva or presentation, publishable summary

IFF Certificate Courses

Practical, practitioner-led certificates designed for immediate on-the-job application. Each course can stand alone or act as a pathway into our postgraduate tracks.

Dimension Conducting a Transfer Pricing Trial Effectively Managing Tax Teams Indirect Taxation Tax Risk Management
Jurisdictional audience Global audience Global audience Global audience, with local adaptation Global audience
Ideal for In-house tax, TP managers, litigators, advisors preparing for audits, ADR, trial Heads of tax, managers, team leads, controllers, emerging leaders VAT, GST, customs, finance managers, AP, AR, compliance specialists Tax managers, risk officers, controllers, advisors building governance
Core focus Case theory, evidence files, expert reports, witness prep, courtroom strategy Operating models, KPIs, workflows, stakeholder management, coaching VAT design, place of supply, input credits, exemptions, WHT interactions Risk identification, controls, documentation, audit readiness, dispute playbooks
Delivery mode Online, live sessions plus guided self-study Online, live sessions plus guided self-study Online, live sessions plus guided self-study Online, live sessions plus guided self-study
Duration 16 weeks, part-time 16 weeks, part-time 16 weeks, part-time 16 weeks, part-time
Outcomes Confident litigation preparation and defence for TP disputes Stronger execution, clear roles, measurable team performance Reduced VAT errors, better cash flow, fewer surprises at audit Structured governance, fewer findings, faster dispute resolution
Prerequisites TP fundamentals recommended Supervisory experience helpful Basic VAT knowledge helpful General tax experience helpful
Pathway Progress to PG Certificate in Transfer Pricing Progress to Mechanics of Leading Tax Teams, PG Certificate (leadership) Progress to PG programmes, International Tax or SA Tax Law Progress to PG Certificate in International Taxation or Transfer Pricing
Assessment End of module progress assessment

5000-word assignment if PG-Cert option elected
End of module progress assessment

5000-word assignment if PG-Cert option elected
End of module progress assessment

5000-word assignment if PG-Cert option elected
End of module progress assessment

5000-word assignment if PG-Cert option elected