Welcome to ADITextra – the new blog for ADIT students from Extratax Training. Here you’ll find out what’s been happening in our online ADIT courses each week.
You’ll learn more about our study programmes and how we support your ADIT journey. And if you’ve chosen the self-study option for your international tax exams, you can follow our training schedules as a guide to keep you on target.
Each week, we’ll select a key topic from one of the classes for the Spotlight section. We’re starting with Fundamental Sources, Part I of the Transfer Pricing syllabus. Find more information and watch part of the lecture in Section 5 below.
The live tuition classes for the June 2021 exam session started this week. The exams are four months away – it might seem like a long time, but the weeks will soon pass and it’s important for you to get started as soon as you can.
If you’ve registered as a candidate for the Advanced Diploma in International Tax, but are not sure where to start, check out our blog on your first steps.
1. Transfer Pricing
We kicked off the semester on Tuesday with the ADIT Transfer Pricing module, taught by James (Jimmy) Ryan. Jimmy has a wealth of knowledge about transfer pricing. In addition, he’s highly engaging and invests in his own continuous learning to share the latest information with his students. Firstly, he gave a warm welcome to his new ADIT students.
After setting the scene, Jimmy dived into the ADIT syllabus, covering fundamental sources. Then he moved on to introduce the core transfer pricing principles of ‘associated enterprises’, the ‘arm’s length principle’ and comparability. This week, the spotlight is on fundamental source for transfer pricing. Check out Section 5 below to learn more and watch part of the class.
It wasn’t long until we received our first piece of feedback. During the class break, one of the students emailed to say “Jimmy is great!” That’s what we love to hear, as it’s all about delivering a valuable training experience to ADIT candidates.
Recording of Live Classes
Once the live class ends, it is Holly’s time to shine. Holly is the course co-ordinator and uses her video editing skills to turn the two-hour live class into four bitesize videos. Our students can watch the videos any time, and as often as they like, to improve their understanding or revisit a key topic.
There’s still time for you to join the Transfer Pricing course – we’re accepting bookings until 8 March. You can catch up on the classes by watching the recordings and you’ll have one-to-one access to Jimmy and the team to get you fully up to speed.
2. Principles of International Tax
Jimmy was back on Wednesday to begin this semester’s Principles of International Tax course. Straightaway, he greeted the brand new students to Extratax Training and welcomed back some familiar faces from the 2020 Transfer Pricing class.
After an introduction to the course, Jimmy explained the legal concepts around jurisdiction to tax – i.e. how do you assess a state’s jurisdiction to tax an individual or entity? Of course, he quickly referred to the OECD’s Model Tax Convention. Obviously, understanding the Model Tax Convention and its impact on international tax is fundamental to the course.
One of Jimmy’s key skills is explaining international tax case law, summarising the facts and highlighting the importance of the decision. As the class progressed, he discussed significant cases in this area, including the UK Court of Appeal’s decision in Jimenez -v- HMRC.
Then Jimmy shared an overview of the topics to be covered in more detail in later sessions. These are the foundations for understanding and applying international tax law – source taxation, personal residence, domicile, corporate residence and treaty tie-breakers on residence.
After the Online Class
At Extratax Training, we focus on bringing tax professionals from around the world together into a global community. So it was fantastic to see the Principles of International Tax participants immediately starting to use our learning portal to ask the tutors questions and support each other through their ADIT studies.
Naturally, the learning doesn’t stop when the class ends. In order to succeed, the participants have to spend time on recommended reading for this week’s topics and prepare their first weekly assignment. It’s important to balance reading the permitted texts, and other materials, with practicing questions. Above all, we help you focus on the fundamental areas to study and improve your exam technique.
It’s not too late for you to join the Principles of International Tax course – you can book online until 8 March. And don’t worry, you can catch up on the classes by watching the recordings. Plus you’ll have one-to-one access to Jimmy and the team to get you fully up to speed.
3. UK Tax
Next, it was time for the UK Tax class on Thursday. Our founder, Catriona Loughran, is the lead tutor for this course. She’s an experienced UK & international tax specialist, with over 20 years’ experience spanning professional practice, HM Revenue & Customs and in-house tax for multinationals.
Our UK Tax course is designed to be suitable for tax professionals with little or no UK tax experience. We love bringing together candidates from across the globe to study the UK module. Therefore, it was fantastic to welcome ADIT students from the United States, Netherlands and Zambia, along with their UK counterparts.
The United Kingdom
So, where do you start with the ADIT UK module when the syllabus is so broad? Well, Catriona started by looking at the United Kingdom itself. If you’re from the UK, you probably assume that everyone knows which territories form part of the UK, but do they? England, Wales, Scotland and Northern Ireland are the easy ones, but what about, say, the Isle of Man? It could well feature in an ADIT exam question. So, it’s important to know that, while it is deemed to be part of the UK for VAT purposes, it’s otherwise a separate state. It has its own tax laws and double taxation agreements with the UK.
Because this was an introductory session, the focus was on giving an overview of key topics to be covered in future weeks. As you might expect, there was a high degree of overlap with Jimmy’s Principles of International Tax topics – double taxation, source taxation, personal residence, domicile, corporate residence and treaty tie-breakers on residence – but considered from a UK perspective.
The ADIT UK Tax syllabus states that candidates are expected to have some understanding of the major UK treaties, with the US, Netherlands, France and Germany mentioned in particular. Therefore, Catriona makes sure that she references the terms of these treaties when discussing subjects such as the implementation of the Multilateral Instrument in the UK.
Thursday’s class was an engaging and interactive session. The participants benefitted from being part of a small learning group, asking questions when they wanted Catriona to clarify a point or give an example to illustrate a concept.
Extratax Training has produced its own set of e-learning materials, written specifically for UK Module 2.09 by leading international tax experts. After the class, Catriona set the chapters to be completed this week, along with the first weekly assignment. There’s a Brexit theme this time, as the students have to advise a UK plc on repatriating funds from its German subsidiary pre- and post-31 December 2020.
You can still choose to join the UK class – the deadline to book is 8 March. You can catch up on the classes by watching the recordings. Plus you’ll have one-to-one access to Catriona and the team to get you fully up to speed.
4. US Tax
Although there were no classes on Friday, it was a great day for ADIT education! Catriona engaged an excellent US & international tax practitioner to lecture the ADIT US Tax module. We’re excited to be able to welcome ADIT students studying US Tax for the first time.
Live online classes are starting on Thursday 11 March. Follow us on LinkedIn, as we’ll reveal more in the coming weeks.
As the US Module 2.10 is new to our portfolio, we’re offering you the opportunity to book for June 2021 at a special introductory rate.
5. Spotlight on Transfer Pricing – Fundamental Sources
Each week, we’ll put the spotlight on a topic covered in one of our classes. Firstly, let’s look at Fundamental Sources from the Transfer Pricing course.
There are six fundamental sources listed in the ADIT Transfer Pricing syllabus:
- OECD Model Tax Convention & UN Model Tax Convention – particularly Article 9 on ‘Associated Enterprises’ and the references to a ‘special relationship ‘ in Articles 10 – 12
- The OECD 2017 Transfer Pricing Guidelines
- OECD 2015 BEPS (Base Erosion & Profit Shifting) Final Reports on Actions 8 – 10 regarding transfer pricing
- The transfer pricing legislative cases listed in the reading list (page 64 of the syllabus)
- The EU Joint Transfer Pricing Forum (JTPF) Codes of Conduct guidelines and reports
In addition, don’t forget about the new Chapter X of the Transfer Pricing Guidelines – Transfer Pricing Guidance on Financial Transactions. The OECD released this report in February 2020. As new guidance, it is highly examinable. You should make sure that you understand the guidance and its application.
The syllabus lists the report as a Permitted Text for the Transfer Pricing exam, so you can bring an authorised copy into your exam room and refer to it in your answers. However, you won’t gain any marks by copying from the text. To pass, you’ll need to be able to discuss it and apply it to a scenario.
Article 9 – Associated Enterprises
Watch this excerpt from this week’s Transfer Pricing class to learn about Article 9 of the OECD Model Tax Convention. Also, you’ll hear Jimmy give a succinct definition of transfer pricing. Learning to explain complex topics in a concise manner is a key skill to master for the ADIT exams.
There’s still time to join our Transfer Pricing course – book today and let us guide you to ADIT success.
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