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This article discusses the permitted text books for the ADIT International Tax exams.

 

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ADIT Permitted Text

The syllabus for each ADIT module lists books which you are permitted to bring into the exam hall to use as reference materials during the examinations (known as a Permitted Book or Permitted Text). You should include the costs of buying at least some of these Permitted Texts when evaluating the costs associated with ADIT.


It is possible to obtain free online copies of some of the materials, e.g. the UN Model Convention & Commentary, to use in your studies. However, it is not possible to bring printed versions of these materials into the exam centre, as all Permitted Texts must be bound books.


As a minimum, you should purchase the latest version of  the relevant volumes of ‘Materials on International, TP and EU Tax Law’ by Kees Van Raad. These are available to buy from the International Tax Center Leiden‘s webshop at https://webshop.itc-leiden.nl/.

The volumes and current prices for the Kees Van Raad materials are:

Volume A is essential for Principles of International Taxation and many of the optional ADIT papers, including the jurisdictional options. Volume B is essential for the Transfer Pricing module. Volumes C1 & c2 are essential for the EU Direct Taxation module.

Buying all four volumes of Materials on International, TP and EU Tax Law currently costs €190 plus postage. These materials are a good investment for any practitioner of international tax, whether or not studying for ADIT.

 

We’re always happy to answer questions about our online ADIT training courses and give you the benefit of our ADIT experience. Email us at info@extrataxtraining.com or start a conversation with our founder, Catriona Loughran, on LinkedIn.

Visit our ADITextra blog to find out what our ADIT students have been studying this semester.

Welcome back to ADITextra – the new blog for the ADIT community 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. This week, it’s the UK’s Statutory Residence Test – learn more in Section 5 below.

 

1. Transfer Pricing

Tuesdays are Transfer Pricing day at Extratax Training, with James (Jimmy) Ryan sharing his TP expertise. In Week 2 of this semester’s course, Jimmy talked about the methods set out in the OECD Transfer Pricing Guidelines:

Traditional Transaction Methods

    • CUP – Comparable Uncontrolled Price
    • RPM – Resale Price Method
    • Cost Plus

Transactional Profit Methods

    • TNMM – Transactional Net Margin Method
    • Profit Split Method

 

Taking each method in turn, Jimmy used examples to explore when each method would be appropriate and the factors to consider when using it. This is important because, in the exam, you’ll be required to advise on the most appropriate TP methods for the scenario before you. You need to apply the Transfer Pricing Guidelines and understand how the methods work in practice.

 

It’s not about repeating the wording of the Transfer Pricing Guidelines. It’s all about applying your transfer pricing knowledge.

 

Building an ADIT Community

Although it’s only the second week of the course, the Transfer Pricing students are already bonding over their shared ADIT experience and supporting each other with their learning. This is great to see, as building a global ADIT community is one of our key aims at Extratax Training.

 

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

Wednesdays mean that Jimmy’s back for Principles of International Tax. And our cohort this semester is truly international, stretching from the UK to the UAE, via Germany, Switzerland and Lithuania!

 

This week’s topic was double taxation. After looking at the causes of double taxation, Jimmy moved on to outline methods of relief from double taxation – the credit method, the exemption method – along with the pros & cons of each method.

 

Then Jimmy explained the interaction of double tax relief systems with the concepts of:

Capital Export Neutrality

Requires that sellers/investors face the same tax rate wherever the products are sold, thus maximising the choice of outbound investment opportunities.

 

Capital Import Neutrality

Requires sellers/investors in a particular location to face the same tax rate no matter where they are located, thus maximising the choice of inbound suppliers for consumers, and inbound capital investment, i.e. savers.

 

ADIT Community in Live Classes

Naturally, the students had lots of questions on the topic, leading to an engaging and informative discussion. That’s the benefit of live classes with a small group – you can ask questions to check your understanding and deepen your knowledge.

 

It’s not too late for you to join the Principles of International Tax course and become part of our ADIT community – 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

On Thursdays, it’s time for the UK class, taught by Extratax Training’s founder Catriona Loughran. After last week’s overview session, the focus for this week was the residence of individuals.

 

This is a key topic for the ADIT UK course. It’s fundamental that you are able to identify whether or not an individual is tax resident in the UK in a tax year.

 

Why does residence matter? Because an individual resident in the UK is subject to UK tax on worldwide income and gains (on an arising or remittance basis, depending on domicile statue). While a non-resident is liable to UK tax where there is a UK source.

 

Check out Section 5 below for more details on UK residence for individuals, including an extract from this week’s class.

 

Past Paper Questions

Personal residence could be the starting point for a question, or it could be the main focus. One of the skills that the students will learn through practicing questions each week is how much time to spend discussing residence. It could be easy to devote your whole time for a question to working through the Statutory Residence Test – when the examiner intends you to reach a conclusion within a few minutes and move on to addressing other topics.

This week, the students looked at two past paper questions covering personal residence. During the class, the participants worked through Q9 from the June 2017 exam. Everyone took time individually to think about their approach to the question. Then the class came back together to discuss it. The question generated an interesting discussion, particularly around how to advise the person wanting to leave the UK about maintaining a non-UK resident position.

 

Secondly, the students have part of another past exam question to complete as the weekly assignment. This time, they have to consider the residency position of someone coming to work in the UK. Looking at these two questions will strengthen their understanding of the differences between applying the Statutory Residence Test to someone leaving the UK & someone coming to the UK.

 

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

Next for an update on US Tax. While we’re getting ready for the US classes starting on Thursday 11 March, Catriona took an opportunity to improve her understanding of US transfer pricing. She joined a webinar by Robert Misey on ‘Transfer Pricing for Foreign-Owned U.S. Companies‘. It was an entertaining and educational hour as Robert used practical examples to illustrate the identification of related party transactions and the US rules on transfer pricing methods.

 

The webinar was available for free at the CPA Academy. If you get a chance, you should check it out. Also, look out for other free webinars on the site covering elements of the Module 2.10 syllabus.

 

When studying transfer pricing for the US, or other jurisdiction modules, it is important to think about the domestic rules, including –

  • Which legislation requires the application of the arm’s length principle?
  • What are the exact requirements of the domestic legislation?
  • Which transfer pricing methods are acceptable?
  • Who is a connected party?
  • Are there any exemptions?

 

If you’re familiar with the OECD Transfer Pricing Guidelines, it can be tempting to jump straight into them. The Guidelines are very much the focus of the Transfer Pricing paper. When you are being examined on a specific jurisdiction, your emphasis should be on the transfer pricing rules in that country.

 

If you’re interested in joining us for the US Tax option, we’re offering you the opportunity to book for June 2021 at a special introductory rate to celebrate adding Module 2.10 to our portfolio.

 

 

5. Spotlight on UK Tax – Statutory Residence Test

Each week, we’ll put the spotlight on a topic covered in one of our classes. This time, let’s look at the UK’s Statutory Residence Test (SRT). This forms part of a broader topic on residence, domicile and deemed domicile.

 

Initially, Catriona covered the materials for the students to read on the topic:

 

The good news about the two HMRC documents is that they are contained in Part 2 of Tolley’s Yellow Tax Handbook – a permitted text for you to take into the exam. Of course, it’s important to familiarise yourself with them beforehand and use them as reference tools for applying your knowledge.

 

Schedule 45 to Finance Act 2013

Schedule 45 to Finance Act 2013 introduced a Statutory Residence Test (SRT) with 3 parts:

  • Automatic Overseas Tests

    • If any of these tests are met for a tax year, an individual is conclusively non-UK resident
  • Automatic UK Residence Tests

    • If any of these tests are met for a tax year, an individual is conclusively UK resident
  • Sufficient Ties Test

    • Contains day-counting rules and other connection factors (known as sufficient ties) which only need to be considered by individuals whose residence status is not conclusively determined by the automatic tests.

 

There is guidance on applying the SRT in HMRC’s Residence, Domicile & Remittance Basis Manual (RDRM). For example, refer to RDRM11040 for the steps to be taken to ascertain an individual’s residence status under the SRT.

 

Watch & Learn

Watch part of this week’s UK class to learn about the Statutory Residence Test.

 

 

There’s still time to join our UK Taxation course – book today and let us guide you to ADIT success.

 

Stay Informed

Follow us on social media to keep up to date with our ADIT blogs. And don’t be shy, please say hello, our door is always open to welcome new members to our ADIT community!

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Follow us on LinkedIn, Twitter & YouTube

 

 

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.

 

Interactive Learning

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:

 

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.

 

Stay Informed

Follow us on social media to keep up to date with our ADIT blogs. And don’t be shy, please say hello, our door is always open to welcome ADIT students from around the world!

Visit our website
Contact us

Follow us on LinkedIn, Twitter & YouTube

 

Visit our ADITextra blog to find out what else our ADIT students have been studying this semester.

 

Well done, you took the plunge and registered as an ADIT student for 2021!

There’s a few weeks left before the June 2021 exam entry deadline on 31st March*, so this is the time to get yourself organised for sitting an exam this term.

1. Structuring your exam plan

It’s tempting to go all out and enter for three exams at the outset.  While this may be achievable, you’ll need a great deal of time to commit to studying in order to be successful in all three papers in one sitting.

We recommend taking a maximum of two exams first time round.  You have 5 years initially to complete the qualification, and it’s well worth spreading the workload so that you don’t take on too much at the outset.

Getting to grips with one ADIT module syllabus at a time means you have the space to really apply your learning to your work, as well as keeping that all-important balance between your professional and personal life!

2. Choose your module(s)

As you know, the Principles of International Tax module is compulsory, and you must also sit one jurisdictional paper and one thematic paper to complete the ADIT requirements.  You may write an extended essay in place of one of these modules, which is a great option if you have a particular niche interest or specialism.

It is good to be aware that in June each year there are exam sittings for every paper offered, whereas only a specific set of papers are examined in the December sitting.  Click here and take a look at the ADIT exam information for more details.

With all this in mind, you might want to consider which papers you sit in which season.  There’s a view that Principles of International Tax is a good paper to do first, because it offers a general framework for the exams.  However, if you plan to take a paper in an area in which you already specialise, then you might prefer to take that first as it is likely to give you a strong start on your ADIT journey.

When you’ve decided which module(s) to take, you can enter online here.

*Don’t forget the deadline for entering June 2021 exams is 31st March 2021.*

3. Work out a study schedule

It’s never too early to do this!  If you start now, you will be able to work your way through the module syllabus over the next three months, still leaving yourself time for revision and exam practice before the real thing.

The crucial thing about a study plan is sticking to it.  If it starts to slip, make a real effort to put in the extra time to catch up straight away.  Falling behind on your schedule can make the amount of work required appear more daunting than it needs to be.

If you are one of the many people who find it helpful to learn in a group, or with structured tuition, then choose a registered course provider to help you prepare.

Extratax Training are a registered ADIT course provider.  You can check out our ADIT study programmes here.  All our tuition takes place in live, online classes where we encourage everyone to participate and learn together.  The courses run over a 10 week period, and tutors host intensive revision sessions to consolidate your learning before the exams.

4. Purchase set texts

Now you’re a registered ADIT student, you should buy Professor Kees Van Raad’s Materials on International, TP and EU Tax Law Volume A.  This will be an essential resource all the way through your qualification, so it is money well spent!

Candidates who join one of our Extratax Training study programmes will be provided with a set text to support learning for the module in question.  This is included in the course fee.

*Be absolutely certain you have read and understood the guidelines about marking permitted texts before you write on any of them.*

5. Start learning!

Knowing where to start can be tricky.  Extratax Training take the worry out of this by working through the syllabus logically, and providing a forum for discussion of topical and practical issues.  Our online sessions are a great opportunity for all students to ask questions and to learn from the experience of their international tax colleagues in the seminar.

If you’d like to find out more about joining one of our study programmes as you prepare for your ADIT exams, why not get in touch.

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Visit our ADITextra blog to find out what our ADIT students have been studying this semester.

* The June 2021 ADIT exam entry deadline has been extended from 16th March 2021 to 31st March 2021. If you’re not already a registered ADIT student but want to sit an exam in June 2021, contact the CIOT at education@adit.org to enquire about late registration.

The Chartered Institute of Taxation (CIOT) brought certainty and convenience to students with their welcome decision to move all Advanced Diploma in International Taxation exams online for the June 2021 sitting.

 

Benefits of Online ADIT Exams

This offers you a great opportunity to sit the exams from anywhere in the world, including the comfort of your own home! This is of particular benefit to candidates who otherwise be required to spend time and money travelling to reach an examination centre.

 

Online exams increase the flexibility of this prestigious international tax qualification, making it even more accessible to global tax professionals.

 

Sitting an Online Exam with the CIOT

You will not need to select an examination centre as part of the registration process for your exam.  However, you will need to state where in the world you plan to sit the exam. This is because the exam is made available at specific times in different time zones.

 

You must download the Exam4 software application to sit the online exams.  Using this software, you’ll see your exam paper on one half of the screen while you type your answers on to the other half.  You do not need to remain online for the duration of the timed exam, although you will require access to an internet connection to download the exam and to submit your completed exam paper at the end.

 

To find out more details about the online exam rules and guidance, visit the CIOT website.

 

Online ADIT Courses from Extratax Training

At Extratax Training, a recognised ADIT course provider, all our teaching takes place online to facilitate students from around the world.  Our ADIT tutors offer practical advice and tips on exam technique throughout the courses. They are available to provide you with one-to-one feedback and support.

 

Combining online exams with live-stream online training, you can achieve a gold standard international tax qualification without having to leave the house!

 

What’s stopping you? Get in touch to learn more about our ADIT study programmes and supporting you on your (virtual) ADIT journey.

 

Visit our ADITextra blog to find out what our ADIT students have been studying this semester.

 

Do you want to improve your international tax expertise and gain a globally recognised international tax qualification? Read on to find out about the benefits of the ADIT qualification.

ADIT offers you the opportunity to go beyond your own country’s tax system and learn about how tax systems interact. In an increasingly global world, where even the smallest businesses can use technology to expand overseas, ADIT gives you a robust foundation in international tax to make you stand out from the crowd. There has never been a more exciting time to be an international tax specialist!

ADIT is a practical qualification – combining academic understanding with real life application. ADIT is an advanced level designation in cross-border tax designed by a board of world-leading experts. You may already be working in international tax, having learned ‘on the job’ – the ADIT qualification fills the gaps in your knowledge and identifies you as a true international tax specialist.

CIOT ADIT logo

One of the benefits of ADIT is that it offers a high degree of flexibility, allowing you to balance work & study commitments. The exams are modular, so you can take them in any order or all at the same sitting. You have plenty of time to complete the qualification, with at least 5 years to graduate. To graduate, you must pass the compulsory Principles of International Taxation paper plus two optional modules, or one optional module and an extended essay on the subject & jurisdiction of your choice. The only prerequisite to register as a student & take the exams is an email address!

If your home jurisdiction doesn’t offer a tax qualification on a par with the Chartered Tax Adviser qualification, studying for ADIT and becoming an International Tax Affiliate of the UK Chartered Institute of Taxation is your chance to gain a globally recognised tax qualification. When you become an International Tax Affiliate, you demonstrate your commitment to upholding the highest professional standards, and highlight your technical expertise and dedication to your career.

The core module – Principles of International Taxation – gives you a solid foundation in international tax without focusing on any one jurisdiction. Its syllabus covers key issues such as principles of international tax law, residence, double taxation conventions and treaty interpretation, transfer pricing, the work of the OECD and international tax avoidance.

You have free choice over your selections for the other two modules. You may choose to focus on the thematic papers to further develop your understanding of international tax in specific areas. Or you may choose to learn more about international tax rules in a neighbouring jurisdiction and a common headquarters jurisdiction, like Singapore or the UK. Or you can choose to mix a thematic & a jurisdiction option.

ADIT gives you the flexibility to design an international tax qualification that meets your needs.

The thematic options are:

  • EU Direct Tax – examines the impact of European Union Law on all aspects of direct taxation for all Member States, including the background to EU Law in the Treaties, and the role of the various EU institutions.
  • EU VAT – examines the European Union Law on Value Added Tax (VAT) which governs the VAT system in all Member States, including the fundamental concepts of EU Law, the provisions of the VAT Directive & other EU VAT legislation, and the application of EU Law by the Court of Justice in decided cases
  • Banking – covers international taxation of the banking industry, including investment banking, capital markets, global markets, asset financing, asset management, private banking and wealth management.
  • Upstream Oil & Gas – examines the taxation of upstream oil and gas operations in an international context, addressing fundamental tax issues within the oil and gas sector, including a number of country examples, permanent establishments and transfer pricing methods, the taxation of intellectual property, mergers and acquisitions, financing and trading activities within the sector.
  • Transfer Pricing – covers the fundamentals of transfer pricing based on the OECD model, focusing on transfer pricing methods, the arm’s length principle, comparability, compliance issues and avoiding double taxation and dispute resolution.

The jurisdiction options are:

  • Australia – covers the structure of the Australian tax system with particular emphasis on Income Tax, Fringe Benefits Tax and Goods and Services Tax.
  • Brazil – covers the structure of the Brazilian tax system with particular emphasis on the principle of territoriality, taxation of individuals, companies and non-residents, and Brazil’s international tax treaty network.
  • China – covers the structure of the Chinese tax system with particular emphasis on Individual Income Tax, Enterprise Income Tax, and inbound and outbound investment taxes.
  • Cyprus – covers the structure of the Cypriot tax system, with particular emphasis on Income Tax, Capital Gains Tax and Value added Tax, and topics such as the Cyprus Double Taxation Treaty Network, reorganisations and BEPS.
  • Hong Kong – covers the Hong Kong income tax system as it affects individuals and corporate businesses, with particular emphasis on international trading, and includes various special categories of taxpayer, tax administration, double tax relief and tax planning.
  • India – covers the structure of the Indian taxation system with particular emphasis on income tax (including income tax on capital gains) and wealth tax, and addresses tax jurisdiction (including territoriality), taxation of individuals, taxation of companies, tax planning, use of tax treaties, tax procedures, withholding taxes, and tax administration.
  • Ireland – covers Irish personal, corporate and indirect taxes in an international context, along with double tax relief, reorganisations, transfer pricing, cross border issues and anti-avoidance.
  • Malta – covers the structure of the Maltese tax system with particular emphasis on Income Tax, Income Tax from Capital Gains, Property Transfer Tax, Duty on Documents and Transfers and VAT.
  • Singapore – covers the main income taxation issues typically encountered by global businesses operating in a territorial-based taxation economy that is highly dependent on international trade.
  • United Kingdom – covers areas such as UK CFC legislation, double tax relief, thin capitalisation, reorganisations, transfer pricing, application of corporation tax to cross-border situations and anti-avoidance provisions.
  • United States – covers federal income tax in detail (with particular emphasis on inbound and outbound cross-border situations, US tax treaties, transfer pricing and cross-border mergers and acquisitions), along with the basic rules of, and cross-border issues in, the federal estate tax, the federal gift tax, and state and local taxes.

As an alternative to one jurisdiction or thematic exam module, you have the option of writing a 15,000-20,000 word extended essay. This is a great option if your chosen area of international tax is not covered by an available ADIT module options or if you are completing a dissertation or thesis as part of an LLM or masters degree in international tax – a version of your dissertation or thesis may be submitted in fulfilment of the ADIT extended essay option (provided it meets the ADIT extended essay requirements.) Or perhaps you simply wish to gain the experience of researching and writing an advanced level extended essay that contributes to the academic discourse in a specialist area of international tax?

Did you know that you can also obtain modular and standalone certificates from the CIOT?

ADIT students who successfully complete Principles of International Taxation and one optional module may apply for a modular certificate recognising their partial ADIT achievement. Students who pass either Principles of International Taxation or a thematic module can alternatively apply for standalone certification. The modular certificate is a great option to demonstrate your growing expertise as you work towards becoming an ADIT graduate.

The standalone certificates are ideal if you are interested in gaining a qualification in one specialist area of the ADIT syllabus, for instance, transfer pricing. Or maybe you are already an ADIT graduate but wish to continue to expand your international tax knowledge by studying a further thematic module!

If you’d like to know more about the investment involved in achieving the ADIT international tax qualification, check out this article on the costs of studying ADIT.

Are you trying to decide between the ADIT & CTA qualifications? Read our useful CTA versus ADIT comparison here.

Think ADIT could be for you? Get in touch with your questions & to discuss our ADIT training solutions.

At Extratax Training, we  offer live online training courses for:

Principles of International Taxation

UK Option

US Option

Transfer Pricing Option 

We’re always happy to answer questions about our online ADIT training courses and give you the benefit of our ADIT experience. 

Email us at info@extrataxtraining.com or start a conversation with our founder, Catriona Loughran, on LinkedIn.

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Visit our ADITextra blog to find out what our ADIT students have been studying this semester.

The battle of the professional tax qualifications – CTA versus ADIT!

 

This is a question we often get asked – Which is the best qualification for my tax career – ADIT International Tax Affiliate or CTA Chartered Tax Adviser?

The answer, of course, is – it’s not a battle. There’s no CTA versus ADIT. It’s about which is best for you now. Read on for tips on how to make your decision.

 

 

Are you trying to decide on the next step to develop your tax expertise? Not sure if you should study for the CTA qualification or choose ADIT to specialise in international tax? This article discusses the key points of each qualification to help you decide on your best option. 

Both are attractive qualifications which will benefit your tax career. The right choice for you is likely to be based on the stage of your career and where you want to go from here!

 

CTA – Chartered Tax Adviser

Originating with the UK’s Chartered Institute of Taxation, Chartered Tax Adviser (CTA) is the leading qualification in professional tax expertise. It is internationally respected as a mark of technical excellence and professional integrity. Becoming a Chartered Tax Adviser requires an in-depth knowledge of tax legislation and its application to real life scenarios. A CTA can be relied upon to provide the highest quality tax advice to businesses and individuals.

The Chartered Tax Adviser qualification has increased in global recognition in recent years, with the CIOT licensing use of the CTA designations to the Irish Tax Institute, the Tax Institute in Australia and, more recently, the Taxation Institute of Hong Kong. CTAs are members of one of these highly respected professional bodies, which share a commitment to pursue efficient tax systems.

CTAs follow a code of practice requiring them to advise only in areas where they have the geographical and technical expertise. For example, a CTA advising on UK corporate taxes must have expert knowledge of the UK corporate tax system. Similarly, a CTA practising in Ireland, Australia or Hong Kong and advising on corporate taxes is required to have expert knowledge of the corporate tax system in the relevant jurisdiction.

UK CTA Structure

Access to the CTA qualification is open to anyone and there is no requirement to have a prior qualification. However, the examinations are set at a high standard. To give yourself the best chance of success, if you don’t already have a previous qualification in accounting or law, the recommendation is to register for the Tax Pathway route to qualification. The Tax Pathway is a route to membership of both the Association of Taxation Technicians and the CIOT. It brings together the exceptional tax compliance knowledge delivered by the ATT qualification with the CTA, the mark of quality for tax professionals.

There are four parts to the CTA exams in the UK:

  • Computer Based Exams – compulsory:
    • Principles of Accounting
    • Law
    • Professional Responsibilities & Ethics
  • Awareness – choose 3 of 5 modules (not to be the same as the corresponding Advanced Technical papers):
    • Taxation of Individuals
    • Inheritance Tax, Trusts & Estates
    • Taxation of Unincorporated Businesses
    • VAT including Stamp Taxes
    • Corporation Tax
  • Advanced Technical – choose 2 out of 7 papers (not to be the same as the corresponding Awareness modules):
    • Taxation of Individuals
    • Inheritance Tax, Trusts & Estates
    • Taxation of Owner Managed Businesses
    • Domestic Indirect Taxation
    • Cross-Border Indirect Taxation
    • Taxation of Major Corporates
    • Human Capital Taxes

Note: the Advanced Technical papers are changing in 2021.

  • Application and Professional Skills – choose 1 of 6 options:
    • Taxation of Individuals
    • Inheritance Tax, Trusts & Estates
    • Taxation of Owner Managed Businesses
    • VAT & Other Indirect Taxes
    • Taxation of Larger Corporates & Groups
    • Human Capital Taxes

As you can see, the CTA structure allows you to choose areas of tax specialism (e.g. owner-managed businesses, employment & global mobility, VAT) while ensuring that you have a good awareness of the wider tax system. Studying to become a Chartered Tax Adviser gives you the building blocks for a successful career in tax, including developing skills like understanding tax legislation and interpreting case law. Many roles in the tax profession list being a CTA as one of the essential criteria – showing its value in the market.

Studying for CTA requires a significant time commitment and can be difficult to achieve without your employer’s full support, both financially and granting study leave. The CTA papers are designed around a tax adviser in practice giving advice to external clients and you may find this a greater challenge if your background is in-house tax, which tends to be more hands-on and practical. If you already have the CTA or equivalent qualification in one jurisdiction you will have transferable skills & knowledge and, depending on the role you’re seeking, may not need to sit the CTA exams in another jurisdiction.

 

 

ADIT – International Tax Affiliate

ADIT offers an opportunity to go beyond your own country’s tax system and learn about how tax systems interact. In an increasingly global world, where even the smallest businesses can use technology to expand overseas, ADIT gives you a robust foundation in international tax to make you stand out from the crowd.

ADIT is a practical qualification – combining academic understanding with real life application. You may already be working in international tax, having learned ‘on the job’ – the ADIT qualification fills the gaps in your knowledge and identifies you as a true international tax specialist.

If your home jurisdiction doesn’t offer a tax qualification on a par with Chartered Tax Adviser, studying for ADIT and becoming an International Tax Affiliate of the UK Chartered Institute of Taxation is your chance to gain a globally recognised tax qualification. When you become an International Tax Affiliate, you demonstrate your commitment to upholding the highest professional standards, and highlight your technical expertise and dedication to your career.

CIOT ADIT logo

ADIT offers a high degree of flexibility, allowing you to balance work & study commitments. The exams are modular, so you can take them in any order or all at the same sitting. You have plenty of time to complete the qualification, with at least 5 years to graduate. To graduate, you must pass the compulsory Principles of International Taxation paper plus two optional modules, or one optional module and an extended essay on the subject & jurisdiction of your choice. The only prerequisite to register as a student & take the exams is an email address!

The core module – Principles of International Taxation – gives you a solid foundation in international tax without focusing on any one jurisdiction. Its syllabus covers key issues such as principles of international tax law, residence, double taxation conventions and treaty interpretation, transfer pricing, the work of the OECD and international tax avoidance.

You have free choice over your selections for the other two modules. You may choose to focus on the thematic papers to further develop your understanding of international tax in specific areas. Or you may choose to learn more about international tax rules in a neighbouring jurisdiction, e.g. Ireland, and a common headquarters jurisdiction, like the US or UK. Or you can choose to mix a thematic & jurisdictional option – ADIT gives you the flexibility to design an international tax qualification that meets your needs.

The thematic options are:

  • EU Direct Tax
  • EU VAT
  • Banking
  • Upstream Oil & Gas
  • Transfer Pricing

Which option you choose will be determined by your areas of interest and work experience. Transfer Pricing is becoming increasingly important across the world and remains a top priority for Multi-National Enterprises and Tax Authorities. The EU VAT option is of interest not only to VAT practitioners in the EU, but also those in other regions, like the Gulf Cooperation Council (GCC) member states where recently introduced VAT systems are based on the EU model.

The jurisdiction options are:

  • Australia
  • Brazil
  • China
  • Cyprus
  • Hong Kong
  • India
  • Ireland
  • Malta
  • Singapore
  • United Kingdom
  • United States

Did you know that you can also obtain modular and standalone certificates from the CIOT?

ADIT students who successfully complete Principles of International Taxation and one optional module may apply for a modular certificate recognising their partial ADIT achievement. Students who pass either Principles of International Taxation or a thematic module can alternatively apply for standalone certification. The modular certificate is a great option to demonstrate your growing expertise as you work towards becoming an ADIT graduate. The standalone certificates are ideal if you are interested in gaining a qualification in one area of the ADIT syllabus, e.g. transfer pricing, or if you are already an ADIT graduate but wish to expand your international tax knowledge by studying further modules.

If you’d like to know more about the investment involved in achieving the ADIT international tax qualification, check out this article on the costs of studying ADIT.

At Extratax Training, we  offer live online training courses for:

Principles of International Taxation

UK Option

US Option

Transfer Pricing Option 

 

We’re always happy to answer questions about our online ADIT training courses and give you the benefit of our ADIT experience. Our tutors are qualified in CTA, ADIT or both so we can share our experience with you to help you decide on the best move for your tax career.

Email us at info@extrataxtraining.com or start a conversation with our founder, Catriona Loughran, on LinkedIn.

 

The ADIT qualification offers a fantastic return on investment. This article explains the cost to study ADIT to help you decide on investing in your international tax career.

CIOT ADIT logo

1. Mandatory Fees to Chartered Institute of Taxation

The initial cost of ADIT is registering with the CIOT as an ADIT student. This is a one-off fee of £210. Registration as an ADIT student remains valid for 5 years.

If you are already a member of the CIOT (e.g. a CTA), you may not be required to pay this fee. If this applies, you should contact the ADIT Education Team to discuss registering as an ADIT student.

There is an entry fee of £195 for each exam paper (or the extended essay option). 

Therefore, the total fees for registering as an ADIT student and sitting three ADIT papers are £795. This is a small cost to study ADIT, a highly prestigious international tax qualification.


2. Costs for Permitted Texts

The syllabus for each ADIT module lists books which you are permitted to bring into the exam hall to use as reference materials during the examinations (known as Permitted Texts). You should include the costs of buying at least some of these Permitted Texts when evaluating the cost to study ADIT.


It is possible to obtain free online copies of some of the materials, e.g. the UN Model Convention & Commentary, to use in your studies. However, it is not possible to bring printed versions of these materials into the exam centre, as all Permitted Texts must be bound books.


As a minimum, you should purchase the latest version of  the relevant volumes of ‘Materials on International, TP and EU Tax Law’ by Kees Van Raad. These are available to buy from the International Tax Center Leiden‘s webshop at https://webshop.itc-leiden.nl/.

The volumes and current prices for the Kees Van Raad materials are:

Volume A is essential for Principles of International Taxation and many of the optional ADIT papers, including the jurisdictional options. Volume B is essential for the Transfer Pricing module. Volumes C1 & c2 are essential for the EU Direct Taxation module.

Buying all four volumes of Materials on International, TP and EU Tax Law currently costs €190 plus postage. These materials are a good investment for any practitioner of international tax, whether or not studying for ADIT.

3. Costs of ADIT Course Providers

The most significant part of your investment in your ADIT studies is likely to be the cost of ADIT training courses. There are a variety of options on structure, delivery, pricing etc. and you’ll need to decide which options will give you the best learning experience for your investment.

The CIOT publishes a list of ADIT course providers here. You’ll have to visit their individual websites or contact them for pricing details. The CIOT recommends that you ask questions to evaluate the following factors when deciding on your ADIT course provider:

  • Style
  • Content
  • Success rates 
  • Experience and qualifications held by the tutors

You can find detailed information about the ADIT training provided by Extratax Training at ADIT Courses. We measure success not just in terms of achieving your ADIT diploma or certificate – also by how we increase your international tax expertise to help your career advancement. 

 

4. Benefits of ADIT 

The costs to study ADIT are easier to quantify than the benefits, but we believe that investing in ADIT offers a significant return on investment. Our tutors can tell you their personal stories about their ADIT success. If you’d like to hear what senior international tax experts have to say about ADIT, visit the ADIT section of the etaxjobs website to read comments including:

“ADIT provides in-depth knowledge of cross-border tax, invaluable to a global company like Michelin. It enhances the value that I am able to add to the business and provides opportunities to extend my horizons beyond the UK.”

Michelin | Robert Johnstone ADIT, Director of International Taxation | Singapore

“ADIT has a perfectly balanced curriculum which enabled me to study international tax in a systematic manner, and I found that completing my LL.M. was much simpler because of my previous ADIT studies.”

P.R. Bhuta & Co. Chartered Accountants | Harshal Bhuta ADIT, Partner | India

“The addition of the ADIT qualification was a clear choice to enhance our offering as an independent consultancy. It strengthens our own brand, and offers our clients the security that the advice they receive is of an assured, global standard. We have not looked back.”

Priority Tax Consulting | James Ryan ADIT, Principal | Ireland

“In pursuing the ADIT exams, I developed a strong technical understanding of international tax issues, and by successfully completing ADIT I was able to gain the confidence to apply this technical knowledge of important topics affecting my clients, such as transfer pricing and permanent establishments. My success, first as an ADIT student and now as an International Tax Affiliate of the CIOT, has not only assisted my self-development, but has helped me to gain significant recognition as an international tax practitioner.”

Grant Thornton | Quang Tran-Trung Phan ADIT, Tax Manager | Malaysia

 

We’re always happy to answer questions about the cost to study ADIT and give you the benefit of our ADIT experience. Email us at info@extrataxtraining.com or start a conversation with our founder, Catriona Loughran, on LinkedIn.

 

 

 

CIOT has announced the 10th Joint International Tax Conference, being held in London on Tuesday 17 March 2020.

 

This leading international tax conference is jointly arranged by ADIT, King’s College London and the UK branch of the International Fiscal Association. The conference fee is set at an attractive rate of £120 for this full day event, plus there’s a reduced fee of £100 for ADIT International Tax Affiliates and current ADIT students.

 

This upcoming conference follows the inaugural ADIT Conference held in London in September 2019 and offers industry insights and experiences from renowned tax professionals. The event will build on the success of previous International Tax Conference events organised by King’s College and the Chartered Institute of Taxation, and previous joint meetings between IFA and the CIOT’s European Branch.

 

The agenda includes hot international tax topics:

  • Emerging General Anti-Avoidance Rules (GAARs) in international tax
  • Taxation and the digital economy
  • International tax dispute resolution – now and looking forward
  • Tax aspects of future UK trading relations

 

The 10th Joint International Tax Conference takes place in the Great Hall, King’s College London, Strand, London WC2R 2LS. Register online to secure your place at this interesting event.

 

We hope to see you there. Please come and say hello to our founder, Catriona Loughran, who loves to talk about ADIT & international tax!

 

 

Looking for more exam-standard questions as part of your preparation for the ADIT UK Tax exam?

We’ve compiled the list below of recent past paper questions from the CTA Awareness & Advanced Technical papers which overlap with the Option 2.09 syllabus.

You should attempt these questions under exam conditions, being careful to stick to the timing of 1.8 minutes per mark. It’s tempting to read the question & then the answer, and think ‘I would’ve got that point’! You’ll have a much better idea if this is true by writing out your answer and using the marking guides to see how you’ve performed.

 

ADIT UK Tax Exam Questions

  • Individuals, including Globally Mobile Employees

    • Deemed domicile and remittance (Q1 Taxation of Individuals – May 2019 Advanced Technical Paper)
    • Note on ‘Transactions in UK Land’ anti-avoidance (Q2 Taxation of Individuals – May 2019 Advanced Technical Paper)
    • UK employee on secondment to Germany (Q4 Human Capital Taxes – May 2019 Advanced Technical Paper)
    • Individual moving tax residence from UK to Spain (Q5 Taxation of Individuals – November 2018 Advisory Paper)
    • Note on Business Investment Relief for non-UK domiciled individual (Q6 Taxation of Individuals – November 2018 Advisory Paper)
    • Dutch company engaging a UK employee (Q1 Human Capital Taxes – November 2018 Advisory Paper)
    • Global secondments from a UK company (Q3 Human Capital Taxes – November 2018 Advisory Paper)
    • German workers coming to the UK (Q1 Human Capital Taxes – May 2018 Advisory Paper)
    • UK employee relocating to Australia (Q5 Human Capital Taxes – May 2018 Advisory Paper)
    • New Zealand resident spending time in the UK (Q1 Human Capital Taxes – May 2017 Advisory Paper)

 

As the CTA exams focus on specific areas of UK tax, you will find that some of the questions (e.g. Human Capital) require more in-depth knowledge than typically required for the ADIT UK option. Tackling these questions is a good way to confirm your understanding & prepare you for the challenges of the ADIT paper.

 

  • Corporation Tax & Anti-Avoidance

    • Hybrid mismatch & Controlled Foreign Companies (Q4 Taxation of Major Corporates – May 2019 Advanced Technical Paper)
    • Corporate migration (Q5 Taxation of Major Corporates – May 2019 Advanced Technical Paper)
    • Corporate residence, permanent establishment and Withholding Tax (WHT) on royalties & service fees (Q5 Taxation of Major Corporates – November 2018 Advisory Paper)
    • Transfer pricing & Diverted Profits Tax (DPT) (Q6 Taxation of Major Corporates – November 2018 Advisory Paper)
    • Scope of UK corporation tax, entity classification, Controlled Foreign Companies and international financing structures (Q4 Taxation of Major Corporates – May 2018 Advisory Paper)
    • Cross-border dividend, interest & royalty payments (Q3 Advanced Corporation Tax – November 2017 Advisory Paper)
    • Note on Diverted Profits Tax (DPT) (Q2 Advanced Corporation Tax – May 2017 Advisory Paper)
    • Acquiring a group with Controlled Foreign Companies (CFCs) (Q5 Advanced Corporation Tax – May 2017 Advisory Paper)

 

See the CIOT website for the past papers, suggested solutions and candidate scripts. Please remember that the answers will reflect the law at the date of the exam.

 

For information on online training for Module 2.09, click here.

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