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Paper 1: Principles of International Taxation

This module is based on the OECD Model Convention and is compulsory for all candidates. The focus is on 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. Candidates who pass this exam are eligible to apply for a standalone certificate.

The exam consists of two parts.

  1. 1. Part A consists of five essay-type questions worth 25 marks each.
  2. 2. Part B consists of two scenario-type questions worth 25 marks each.

Candidates are required to answer four questions in total, including at least one question from each part. This exam is offered in the June and December exam sessions.

Topics to be examined Weightage
Basic principles of international tax law 20%
Double taxation conventions (DTCs), focusing on the current version of the OECD Model Tax Convention (MTC) 30%
Transfer pricing and thin capitalization rules 20%
International tax avoidance 25%
Miscellaneous topics 5%