Posts

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!

Visit our website
Contact us

Follow us on LinkedIn, Twitter & YouTube

 

 

Why does student feedback matter?

We’re committed to supporting every one of our ADIT candidates on their professional journey.
We believe the best way to do this is to find out what you need to succeed, and to provide it!

 

See what our students had to say on:

 

Choosing an ADIT study provider

I wanted someone to guide me as I had no clue about international tax or the ADIT Program.  Catriona’s openness, willingness to listen and give advice to a complete stranger, whilst not marketing her firm, convinced me to train with Extratax. It ended up being one of my best decisions in 2020.

Everyone is unique.  At Extratax Training we appreciate that the process of learning is different for each individual.  We are very open about the style of tuition and study support that we provide, so that prospective students understand the commitment involved before they book their place.

 

Course logistics

Start the course earlier as the time is too short to exams, especially to allow students without practical background time to catch up.

In response to this feedback, we extended the length of some of our live online classes this year, and included a mid-semester break, as well as the revision weeks we already include at the end of each course.

Most of our students are juggling a career alongside their family commitments.  We want to ensure the Extratax Training programme helps you to enhance your professional development in the most manageable and enjoyable (!) way possible.

 

The structure of the course was extremely beneficial for myself. It helped me to keep on with studies during extremely busy time at work

We spread the live online tuition across a 10 week timetable, and make the slides and recordings of these sessions available for students until the end of the semester.  This aids revision and allows everyone to catch up, or consolidate learning, at your own pace.

 

Tuition & exam practice

Participation from the rest of the students is really helpful because they sometimes bring a different perspective.

Our tutors set assignments and mock exam questions throughout the semester, which are marked and returned.  Everyone is encouraged to ask questions in the live classes, to share experiences and knowledge with their fellow tax students, and seek one to one support from their tutor when they need it.

I liked the ability to ask questions right on spot during classes…

 

Our expertise

The faculty is a big strength in Extratax – very knowledgeable not only on tax but knowing the ADIT program inside out. The advice shared by the Director, who herself is ADIT qualified, was invaluable to me as someone without previous understanding of the programme or the content.

Catriona Loughran and James Ryan lead and teach our ADIT exam study programmes.  Both are experienced international tax professionals, with outstanding practical knowledge in their field.  You can find out more about them on our website.

Find out about Catriona, Founder & Director of Extratax Training
Find out about James, Course Tutor at Extratax Training

You’ve heard enough from us!
We’ll give our students the final say…

 

“I am a 20 years Professor of International Tax Law in Mexico. Finding Extratax Training to prepare me for the ADIT exams was a blessing! They give great personalized teaching, with in-depth information, well organized and up to date.”

“Well structured course with plenty of useful practical tips.”

“I love how, as someone with no previous UK Tax experience or knowledge, the course made it possible for me to actually really understand and grasp the concepts.”

“After the course, I am not only feeling that I am ready for the exam but also see extreme improvements in my technical expertise that I can apply right on spot at my job.”

“The ADIT tutors are very knowledgeable and present the materials and theoretical concepts in a way to facilitate understanding much more easily than just reading them.”

“The classes and e-book are all you need to excel in your exam.
Thanks Catriona & team!!!”

____

If you’d like to join an Extratax Training study programme in preparation for your ADIT exams, get in touch.

Visit our website
Contact us

Follow us on LinkedIn & Twitter

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

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.

Visit our website
Contact us
Follow us on LinkedIn & Twitter

 

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.

error: Content is protected !!