· Web viewINTERNATIONAL TAXATION & OFFSHORE FINANCIAL CENTERS MASTERS PROGRAM (NQF Level 9) The Institute of Advanced Studies (Pty) Ltd in association with The Da Vinci Institute

INTERNATIONAL TAXATION & OFFSHORE FINANCIAL CENTERS

MASTERS PROGRAM(NQF Level 9)

The Institute of Advanced Studies (Pty) Ltd

in association with

The Da Vinci Institute

for Technology Management (Pty) Ltd

offer a

Masters Program on

INTERNATIONAL TAXATION & OFFSHORE FINANCIAL CENTERS

International and Offshore Banking: Masters Program

EXECUTIVE SUMMARY OF INTERNATIONAL TAXATION & OFFSHORE FINANCIAL CENTERS COURSE CONTENT

Course 1: Principles of International Taxation

This course introduces the various factors which must be taken into account in the tax structuring of international operations and transactions.

Topics include types of tax, tax terminology, connecting tax factors, non-tax factors, processing the data, stages in planning, tax diagnostic methods, the selection of the form of an international transaction, operation or relationship.

Course 2: Double Taxation Agreements and Withholding Taxes

This course provides an in-depth study of bilateral and multilateral tax treaties and withholding taxes.

Topics include double taxation and double taxation relief, foreign tax credits, tax sparing, treaty shopping, the rationale of tax treaty models, residence, permanent establishment, income from immovable property, business profits, shipping, inland waterways and air transport, associated enterprises, dividends, interest, royalties, capital gains, personal services, directors’ fees, artists and sportsmen, pensions, capital, exemption method, credit method, non-discrimination, mutual agreement procedure, exchange of information.

Case studies are presented on the withholding tax procedures in the case of dividends, interest, royalties, and other periodic income, as well as the international taxation of business profits.

Course 3: Offshore Financial Centers (Part I): Introductory

This course provides an in-depth comparative analysis of the principal offshore financial centers.

Topics include general surveys of the offshore financial centers, with particular regard to the government, the legal system, the attitude of the government to offshore operations, political and economic stability, licenses to carry on business.

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International and Offshore Banking: Masters Short Program

Course 4: Offshore Financial Centers Part II : Advanced

This course in offshore tax planning deals with the structuring of offshore operations and transactions, as well as a number of special offshore situations, with examples from various offshore financial centers.

Topics include banks and trust companies, insurance companies (including captive insurance companies), shipping and aircraft companies, foreign sales companies, trade preferences, collective investment schemes and societies with restricted liability, taxation in offshore financial centers, double tax treaties of certain offshore financial centers.

Course 5: International Taxation of Trusts, Estates, Inheritances, Gifts

This course covers a number of highly complex legal concepts involving issues of comparative law and taxation, in the areas of trusts, estates, inheritances, and gifts.

Topics include the law of trusts; trust documentation; comparative analysis of civilian and common law entities; asset protection trusts, Statute of Elizabeth, Hague Convention, estate, inheritance and gift taxes, taxation of trusts, offshore trusts.

Course 6: International Anti-Avoidance

This course deals with those domestic and treaty tax measures whereby countries seek to limit the abusive exploitation of the differences in the world’s tax systems.

Topics include the workings of the transfer pricing provisions in various domestic and international tax systems, thin capitalization, controlled foreign corporation legislation, the arm’s length principle, the abuse of law principle, general domestic legal principles, residence shifting, deeming provisions, limitation of benefits articles in tax treaties.

INTERNATIONAL TAXATION & OFFSHORE FINANCIAL CENTERS PROGRAM SYNOPSIS

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Tax Planning

It is both lawful and sensible to arrange business and personal affairs in such a way as to attract the lowest possible incidence of tax. The widening scope of tax laws, the complexity of their provisions, and high tax rates make it more necessary than ever for business enterprises and individuals alike to plan their taxable events with considerable care.

For a commercial or industrial enterprise, an unnecessarily increased tax burden represents a business waste that not only reduces its distributable profits but may well make it uncompetitive.

In the case of an individual, the net return from personal endeavour and the investment of capital is in most countries so severely reduced by the Revenue that the failure to take advantage of potential tax minimisation benefits may have a considerable effect on spending power and accumulated wealth. The omission to anticipate death duties and inheritance taxes will frequently cut an unnecessarily deep wedge into the estate.

International tax planning is tax planning in which factors involving more than one country are included in the original database and an offshore element is introduced as an extension of domestic tax planning.

The different ways in which two or more systems may be linked offer considerable scope for tax minimisation or deferral, particularly where at least one of the countries is offshore, since offshore does, by its very nature, generally refer to a better tax deal in a foreign country.

On the other hand, where a project crosses frontiers, there are far more tax and non-tax factors to be taken into account than in a purely domestic case. It follows that offshore tax planning may often be exceedingly complex.

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The International and Offshore Database

With the expansion of international trade and private foreign investment, it has become increasingly necessary to have access to a database containing general information regarding tax and business laws and practices in foreign countries. This need is catered to by a number of publications and online services, which are of varying degrees of accuracy, completeness, and speed of updating.

However, most of the available information is far from comprehensive, and it therefore follows that one is dependent to a greater or lesser extent on second-hand information.

The difficulty of obtaining adequate information is aggravated in the case of countries where administrative rulings (and even judicial decisions) are not published fully and quickly, where the ultimate tax bill is subject to negotiation (especially where such negotiation is open to graft), and generally where there is a contrast between the printed word and actual practice.

One is thus frequently obliged to obtain advice from experts in foreign countries involved in a proposed arrangement. Depending on the available documentation, it may be desirable to seek such advice at the outset, during the course of the research, or only at a much later stage for the purpose of controlling whether a possible benefit or pitfall may not have been overlooked.

The database required for the design of an offshore tax plan consists of: (a) the facts, (b) tax factors, and (c) non-tax factors.

Planning Factors

In analyzing the tax factors of an international tax plan, it is necessary to examine:

- the domestic internal tax systems of the countries involved in the project; and

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- the manner in which the general rules embodied in such systems are affected by the introduction of the offshore factor.

Non-tax factors may also have to be taken into consideration for the purposes of a proposed offshore tax plan. These can be every bit as important as the tax factors.

The Connecting Factor

The most effective offshore tax plans derive from the ability to sever the nexus or connecting factor with a taxing country in favour of an offshore country or to rearrange the connecting factors in such a way that a lower overall tax burden is suffered. Liability to tax is dependent upon the existence of a connecting factor between a taxing jurisdiction on the one hand and a taxpayer or taxable event on the other.

Even though a taxpayer may stay within the letter of the law, there is usually a limit to the tax minimization steps that may lawfully be taken. Most tax systems contain some general or specific anti-avoidance provisions. The substance versus form rule enables the revenue to disregard appearances and to rewrite transactions so as to reflect the true situation.

In the case of an individual taxpayer, the principal connecting factors are residence, ordinary residence, domicile, and citizenship (nationality). In the case of a company, they are management and control, beneficial ownership, place of incorporation, and location of the registered office. In the case of a trust, they are the place of creation, the applicable law, the place of administration or trusteeship, and the residence, domicile, or citizenship of the beneficiaries or trustees.

Other important connecting factors may be the center of economic interests, the presence of a permanent establishment, and effectively connected income.

The principal connecting factor with regard to a taxable event is the real or deemed source. For example, in the case of profits deriving from the sale of goods, the source might be the place of the execution of the contract, the place where a trader

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or manufacturer employs his capital or where activities are exercised, while in the case of a real property tax or a capital gains tax on the sale of real property, geographic source or situs would normally constitute the connecting factor.

Tax and Non-Tax Incentives

Tax incentives may convert otherwise high tax countries into limited purpose tax havens. Tax incentives are tax concessions that are granted to attract local or foreign investment capital to particular activities or areas. Nearly all countries grant tax incentives of some kind as part of their general or regional economic development programs.

Exchanges of Information

The principal formal exchange of information mechanism is the tax treaty. Most tax treaties contain an article providing for the exchange of information between the competent authorities. Frequently, too, provision is made for the contracting states to render to each other administrative and legal assistance in connection with the assessment and collection of taxes. Informal exchanges of information between the administrations are on the increase.

Structural Strategies

The structural design of an international arrangement may involve one or more of the following:

• the selection of the form of an international transaction, operation, or relationship;

• the selection of a foreign investment country or new country of residence;• the introduction of one or more additional offshore jurisdictions; and joint

ventures.Where all the countries are determined in advance, the planning process may not go beyond the stage of selecting the most favourable form of a transaction, operation, or relationship from the tax point of view. Dividends, interest, royalty

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receipts, and capital gains frequently receive quite different tax treatment at the domestic level and at the treaty level.

Selection of a Foreign Investment Country or New Country of Residence

Where there is a choice between two or more possible opportunities in different countries, it is useful to examine comparative tax burdens in the light of the business considerations.

In deciding between offers to take up shares in companies in different countries, the following considerations should, inter alia, be taken into account:

• the rate of tax imposed on corporate profits in the investment countries under examination;

• whether dividend distributions are subject to withholding taxes, and if so, at what rates; and

• whether any tax credits or deductions are available in the country of residence of the shareholder in respect of taxes paid in the investment countries under examination.

Introduction of Additional Offshore Jurisdictions

It may be prudent to examine the tax savings that may be achieved by the careful selection of the form of an international transaction, operation, or relationship, and then only consider the possible benefits and pitfalls through the introduction of one or more IOFCs.

Joint Ventures

The planner should begin with a close analysis of:• what each of the parties is required to contribute to the venture, • how the profits (if any) are to be divided between them, • how losses are to be borne,• how the venture can be unscrambled.

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Evaluating the International Tax Plan

It is wise to compute all variables as accurately as possible for each of the following hypotheses:

if the plan is not adopted; if the plan is adopted and succeeds; and if the plan is adopted and fails.

Substance versus Form

The rule that the substance of a transaction, rather than its mere form, controls tax liability is one of very wide application. This rule can affect the amount of taxable income arising from practically any type of transaction.

This rule is also applied frequently to settle questions of who is taxable on certain taxable events.

Applicability of Tax Treaties

When relying on a tax treaty, care should always be taken to insure that it is in force and that it applies to the parties. It is always important to check whether there are any new treaties or amending protocols and whether there are any interpretative rulings or official statements concerning the applicability of the treaty.

International Double Taxation

International double (or multiple) taxation occurs when the tax authorities of two or more countries concurrently impose taxes having the same bases and incidence, in such a way that a person incurs a heavier tax burden than if he were subject to one tax jurisdiction only.

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Tax treaties, which are intended to avoid such incidence of double taxation, may inadvertently create opportunities where global tax burdens may be reduced in a manner unintended by the treaty partners.

Reduction in Withholding Rates

Treaties normally also reduce the rate of tax a country is allowed to withhold on income being paid to a recipient in another treaty partner country.

For this type of arrangement to prove efficient, the costs of the structure plus the aggregate tax burden suffered in the third country by the conduit company should not exceed the high tax country’s tax burden.

Business Profits and Permanent Establishments

Tax treaties lay down which country will be entitled to tax business profits that an enterprise of one country makes in the other country. In most cases, this is by reference to whether there is a permanent establishment in such other state. In situations in which companies wish to take advantage of the certainty and better provisions of double tax treaties, the possibility of structuring business transactions with or in a high tax country through a third country with which it has a tax treaty should be investigated in the diagnostic.

The advantage of using a company incorporated in a country with tax treaties is the possibility offered by the treaties to reduce worldwide taxes on business profits, while structuring the operations so as to attract very little tax in the country of incorporation. This is as a function of the provisions of tax treaties that make it possible to avoid tax on business profits in a foreign treaty country.

Treaty Shopping

“Treaty shopping” is the attempt by third parties to benefit artificially from tax treaties intended to benefit the bona fide residents of residents of the two treaty countries.

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Both the OECD Model Income Tax Convention on Income and Capital and the U.S. Treasury Model Income Tax Treaty contain provisions limiting the use of treaty shopping.

Measures to Combat Harmful Tax Practices

Countries that allow their treaties to be used for treaty shopping are directly in the firing line of the OECD attack on harmful tax practices. This makes it sensible to refer the international measures to combat harmful tax practices.

International Offshore Financial Centers (IOFCs)

Andorra, Anguilla, Antigua, Bahamas, Bahrain, Barbados, Bermuda, Belize, Botswana, British Virgin Islands, Brunei, Campione, Cayman Islands, Cook Islands, Costa Rica, Cyprus, Djibouti, Dominican Republic, Ecuador, French Polynesia, Gibraltar, Grenada, Guernsey, Hong Kong, Ireland, Isle of Man, Jamaica, Jersey, Kuwait, Labuan, Lebanon, Lesotho, Liberia, Liechtenstein, Luxembourg, Macau, Madeira, Malaysia, Maldives, Malta, Marshall Islands, Mauritius, Monaco, Montserrat, Namibia, Nauru, Netherlands, Netherlands Antilles, Nevis, Niue, Oman, Panama, St. Vincent, Seychelles, Singapore, Swaziland, Switzerland, Turks & Caicos Islands, United Arab Emirates, Vanuatu

What do the Offshore Centers Offer?

The principal products stocked by the offshore supermarkets are companies and trusts. Offshore companies usually hold investments and may get involved in trading. Offshore trusts protect the ownership of assets and frequently of the companies themselves. The true beneficiaries are usually individuals residing in high tax countries.

Offshore companies and trusts may hold every imaginable kind of asset: real estate, art collections, jewellery, stocks and bonds, insurance policies, contingent claims, in fact anything at all.

Offshore Companies

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No one can count the number of offshore companies, and that number is expanding exponentially. They are put there for a very good reason: An offshore company can be used for any purpose for which a company in a high tax country can be used, and it mostly does not have to pay tax in the offshore jurisdiction. The bulk of offshore companies simply collect income consisting of dividends, loan interest or patent royalties, and license fees. But many are also used for business purposes. Handled correctly, the offshore company plays a turntable role using tax-exempt income to make more tax-exempt income. Apart from tax, an offshore company can be used for other purposes such as privacy and freedom from exchange control, or protection of assets against future developments in the home country. Though companies in most offshore jurisdictions offer basic similarities, there are significant differences. For example, what information must be contained in the bylaws? Can the true promoters and beneficial owners be kept entirely out of the picture? What are the costs of incorporation? How much time is involved, and can it be accelerated? Are there limits on the powers of the company? Is there any limitation of liability? Can there be bearer shares, no par value shares, preference shares, redeemable shares, shares with special rights?

Offshore Trusts and other Offshore ProductsThe wonder product is the offshore trust. The trust concept is over eight hundred years old, older than company law. The trust vehicle, from the tax planning perspective, may allow a taxpayer to break the connecting factor between the trust assets, the taxpayer, and the taxing jurisdiction. A huge and increasing volume of international banking takes place offshore. Indeed it is extremely easy for an individual or a company with acceptable references to open a bank account offshore, and even numbered accounts are possible. In most countries, one of the terms of the relationship between banker and customer is that the banker will keep the customer’s affairs secret. In some tax havens this rule is now being widened and made a marketing feature. However, the whole world is moving, toward greater openness, and severe pressure is currently being brought to bear on onshore and offshore jurisdictions to fight money laundering and to furnish information to the appropriate authorities in other countries. Other products on the shelves of the

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offshore supermarkets are finance subsidiaries, captive banks, captive insurance companies, shipping and trans-shipment companies, licensing companies, headquarters companies, limited liability companies, foundations, management services companies, manufacturing and export bases, and tax shelters.

Captive BanksA captive bank is a banking subsidiary set up in a tax haven or financial center that operates principally for the benefit of the members of a multinational group and their customers and suppliers. Such captive banks may also operate as merchant banks and offer commercial banking as well as financing services.

Captive Insurance CompaniesSimilarly, a captive insurance company is an insurance company that is fully owned (directly or indirectly) by a non-insurance commercial company and exclusively insures or reinsures the risks of the parent company and/or its affiliated companies. The function is thus one of self-insurance from the group point of view. Captives are now becoming more and more commonplace.

Offshore ShippingOwing to the innate mobility of the shipping industry, it has always been normal practice for ship owners and operators to have recourse to tax havens. Frequently, the ownership, operation, administration, and registration are situated in fiscally favourable (and often different) jurisdictions in order to keep global tax burdens at a low level. The list of flags of convenience countries gets longer every year.

Offshore LicensingTechnology that can be the subject matter of licensing covers all forms of industrial enterprises. It embraces industrial property that may be protected by patents, trademarks, etc., as well as technology that cannot be patented. Certain countries are grand masters of the international royalties game, owing to their wide networks of treaties and the special concessions at home. And an increasing number of

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cinema and television companies are joining the ranks of the technology companies in exploiting these opportunities.

Headquarters and Management OfficesHeadquarters offices are offices situated abroad to exercise certain management, co-ordination, and control functions for the sole or principal benefit of an enterprise or group. Headquarters offices may benefit from a favourable tax regime even in an otherwise high tax jurisdiction. The competition between these countries is resulting in the de facto introduction of more and more favourable tax regimes through what may amount to a partial system of unpublished revenue rulings.

Tax SheltersOne of the main features of high tax systems with offshore potential is the tax shelter, which is really an investment with a flow-through of tax benefits. Artificial losses may be offset not only against income from the investment out of which they arise, but also against the taxpayer’s other income, usually from his regular business or professional activity. Skilled players are able to sit tight onshore and simply let tax shelters transform their onshore earnings into offshore earnings.

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INTERNATIONAL TAXATION & OFFSHORE FINANCIALCENTERS FRAMEWORK

Module Learning Outcomes

Method of International Tax

Planning

After completing this module, participants should be able to advise and assist clients with the following:

Tax planning International tax planning Definitional content of international tax terms Connecting factor Legal status of a taxpayer Source of income or gain Nature of a transaction or operation Relationship of a taxpayer to another person International anti-avoidance Informal exchanges of information Choice of law in international tax planning Foreign currency gains and losses Procedural matters in international taxation International database Treaty provisions for exchanges of information Conflict of laws Private international law Gift planning Donations planning Immigration and emigration Residence of corporations

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Double Taxation Agreements - Tax Treaties


International double taxation Withholding taxes Double taxation agreements (DTAs) OECD model tax convention Connecting factors in tax treaties Relief provisions in tax treaties Treaty shopping limitations Permanent establishment concept Dependent and independent agents Exchanges of information

International Planning Strategies

for Companies


Offshore banking Offshore multi-currency management center Offshore brokerage and securities operations Commodities or financial futures Debt factoring Leasing and plant rentals Offshore trading operations Intangibles Joint ventures and partnerships International construction operations Mail order trading center Offshore purchase and sales companies Assembly and testing operations Research and development (R&D)

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for Companies(cont)

Offshore shipping operations Offshore provision of international services Headquarters, administrative offices, management

companies Coordination centers Offshore licensing Captive insurance and reinsurance Risk shifting and risk distribution Offshore funds Umbrella offshore funds International investment trusts Initial public offerings (IPOs) / listings on foreign

exchanges Secondary or dual floatations Licensing Franchising Purchase and sales Plant rentals Testing operations Shipping operations Flags of convenience International services Offshore investment trusts Residence of corporations

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for Individuals


The international person Emigration Artists and athletes Residence Domicile General principles absent a tax treaty Residence position where a tax treaty is applicable Article 4 of the OECD model and commentary How the residence tiebreakers work Residence planning Estate planning Citizenship and passports Acquiring a new citizenship Types of passports Expatriate remuneration Employment structure and remuneration policy Tax considerations Non-tax considerations Exchange control Contractual relationship between the employer

company/ies and employees Contractual relationship between the headquarters

company and local companies Remuneration packages of offshore employees Conditions of employment

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Offshore Jurisdictions


Offshore – definitional content of term Tax havens International offshore financial centers (IOFCs) IOFC structures, types of IOFC programs Costs and related considerations Offshore entities and vehicles IOFC non-tax features Legal and administrative systems Political and economic stability Professional, commercial, and banking facilities Business climate Incentives Position of foreigners Communications Markets Labour Accountancy laws, procedure, and customs Languages Exchange control Tax shelters International anti-money laundering arrangements


Preferential tax regimes in the fields of insurance, financing and leasing, fund management, banking,

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Incentives and Grants

Incentives and Grants (cont)

headquarters, distribution centers, service centers, shipping, and other miscellaneous activities

Tax exemption (tax holiday) Deduction from the taxable base Reduction in the rate of tax Tax deferral Categories of tax incentives Depreciation allowances Tax shelters Tax sparing Depreciation allowances Banking and other financial incentives Industrial development grants Machinery and plant incentives Industrial buildings incentives Staff training incentives Regional development grants and incentives Export incentives Export sales relief incentives Export credit guarantees Pioneer industries incentives Free zones and free ports Venture capital incentives Research and development (R&D) incentives Patents incentives Urban renewal incentives Joint ventures incentives Film production incentives Capital assistance schemes incentives Operational headquarters incentives Development grants

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Offshore Treasury Management

Strategies


Offshore treasury management strategies Purchases and sales Multicurrency management Interest received or paid Debt factoring Advertising Transport, distribution & handling Travel Communications Captive insurance & reinsurance Royalties Computer services charges Professional services Training Staff recruitment Printing and stationery Sales Recruitment

Transfer PricingAfter completing this module, participants should be able to advise and assist clients with the following:

Arm’s length principle OECD model tax convention OECD transfer pricing guidelines Commentary on the arm’s length rule Transactional and open market features Comparability and subjective elements

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The need for a functional analysis Transfer pricing strategies Transfer pricing four-step methodology Transfer pricing calculations Comparable uncontrolled price (CUP) Resale price method Cost-plus method Alternative methods of transfer pricing calculation Mixture of basic transfer pricing methods Profit comparison and return on capital invested Profit split and unitary methods Return on capital invested Transfer pricing strategies for intra-group services Intra-group services Services that provide incidental benefit Determining arm’s length charges Substance versus form

Electronic Commerce

(e-commerce)


E-commerce OECD taxation framework Permanent establishment and the OECD

commentary OECD’s technical advisory group on treaty

characterisation of e-commerce payments Embedded software TAG Organisation for economic cooperation and

development

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Internet as a Research Tool

After completing this module, participants should be able to understand and navigate:

Types of information on websites Domestic tax law and practice International tax law and practice Case law Tax and other incentives Pending changes Tax treaties Non-tax factors Quality of information on websites Government and Revenue websites

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JOINT MASTERS DEGREE (NQF Level 9) PROGRAM OF

DA VINCI INSTITUTE AND INSTITUTE OF ADVANCED STUDIES

DA VINCI INSTITUTE FOR TECHNOLOGY MANAGEMENT MASTERS PROGRAM

Purpose

The Da Vinci Institute of Technology Management provides a structured International Taxation and Offshore Financial Centers program that has credit carrying components and can lead towards a Masters (NQF 9) in the Management of Technology and Innovation (potentially 108 credits). The full Masters program provides for 240 credits at exit Level 9.

A further purpose of this program is to produce leaders who are equipped to initiate socio-economic transformation in South Africa and abroad in these specialist fields. This should contribute towards the development of individuals, organisations and the community, and equip them to deal with challenges related to the management of technology, international tax planning, the management of innovation, the management of people and systems thinking.

Objectives

The Learning Program is specifically designed to enable participants to realize their true potential by:

Developing them to lead multi-discipline teams tasked to facilitate business success and socio-economic transformation

Acquiring the competence to lead a system (resources) and to develop technology and innovation related activities to meet their professional and business objectives

Providing personal development opportunities for them to contribute significantly to the development of wealth within the South African economy.

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Program Level Descriptors

At the Masters Program Level, Da Vinci provides a structured learning environment within which students develop the capacity to:

Operate in variable and unfamiliar learning contexts, requiring responsibility and initiative

Accurately self-evaluate, identify and address their own learning needs Interact effectively within a professional as well as within a learning group.

Within this contextual environment, while we expect far more integration, we still require that students translate their theoretical understanding of the specific subject matter into demonstrated application back at the workplace such that they show their ability to:

Integrate a well-rounded and systematic knowledge base in one or more disciplines or fields

Provide detailed knowledge and understanding of specialist areas Develop a coherent and critical understanding of:

o Advanced concepts, principles and theorieso Conceptual thinking around the discipline or fieldo An ability to map new knowledge onto a given body of theoryo An acceptance of a multiplicity of “right”, even “possible” answers

Effectively select and apply:o The central methods of enquiry and research in a discipline or fieldo The essential procedures, operations and techniques of a discipline or

field, ando A knowledge of at least one other discipline or field’s mode of enquiry

Deal with unfamiliar concrete and abstract problems and issues using evidence-based solutions and theory-driven arguments

Display well-developed information processing:o Information retrieval skills

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o Critical analysis and synthesis of datao Quantitative and qualitative methodologieso Data presentation skills following prescribed formatso Using IT skills appropriately

Present and communicate both information and their own ideas and opinions in well-structured arguments:

o Showing awareness of audience, ando Using academic or professional discourse appropriately.

The Masters Program requires integration, often across functions and very definitely systemically within functions. The theories are applied cross-functionally in the workplace and the integration of the system as a whole becomes important. Processes are designed to meet specific requirements and students work at a fairly high conceptual level before translating theory into action. They work actively through groups and develop solutions rather than solve problems. Problem solving is non-linear, often chaotic and integrates sometimes obscure and abstract theories but solution processes are designed to meet constantly changing needs.

Access

PreviousAcademic

Qualifications

Appropriate Work

Experience (years)

Employer Support Conditions

1

Diploma MOTI Level 6

orAny other relevant

NQF 8qualification

5

3

General

General

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2None, or not

equivalent to NQF 8 qualification

7 Detailed Assessment

Provisional approval on the following conditions: Demonstrate an understanding at NQF

Level 8 (appropriate level descriptors will be used to guide the process).

evidence of relevant publications, presentations or relevant working experience that could be considered for recognition of prior learning at NQF Level 9*

Registration for the Research Workshops Acceptance of a Research Proposal Completion of the first three modules

On successful completion of the above, provisional approval will be converted to full approval.

In the event that a student is unsuccessful in completing the above, such student will be de-registered for the relevant program.

International Taxation & Offshore Financial Centers Competencies – Masters Program

International and Offshore Banking: CREDITS

Method of International Tax Planning 12

Double Taxation Agreements (DTAs) 8

International Planning Strategies for Companies 8

International Planning Strategies for Individuals 8

Offshore Jurisdictions 8

Offshore Treasury Management Strategies 8

Transfer Pricing 8

Total Credits 60

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SYSTEMS AND FOUNDATIONAL COMPETENCIES (30 credits)

(SOS) Self, Other and Social Contexts (10 credits)

(PCD) Problem Solving, Creative Thinking and Decision Making (6 credits)(PWP) Professional Writing and Presentation (2 credits)

The PWP assignment is compulsory to pass the PCD component(MSW) Managing the Systems Way (12 credits)

DA VINCI CORE COMPETENCIES (30 credits)

(MOI) Management of Innovation (10 credits)

(MOT) Management of Technology (10 credits)

(MOP) Management of People (8 credits + 2

credits)(MLC) Management and Leadership Competencies Final (2 credits)

The MLC assignment is compulsory to pass the MOP component

Total Credits = 60 credits

DISSERTATION – RESEARCH CURRICULUM CREDITS

Integrated International Taxation & Offshore Financial Centers 48

(ELA) Exit Level Integration Assignment. 10

Dissertation 62Total Credits awarded towards Dissertation 120

Research Project CREDITS

Integrated International Taxation & Offshore Financial Centers Research Project 48

Total Credits awarded towards Masters Qualification 108Program Structure

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Students who successfully complete the Post Module Assignments and Research Project for the International Taxation & Offshore Financial Centers component will receive 108 credits towards a Masters in the Management of Technology and Innovation (MOTI). On successful completion of the program students receive an exit level certificate at a formal graduation ceremony.

Successful candidates may elect to complete the full 240 credit Da Vinci Masters in the Management of Technology and Innovation (MOTI) in the domain and qualification of International Taxation & Offshore Financial Centers.

INSTITUTE OF ADVANCED STUDIES

Strategic Vision and Mission

The vision of the Institute is to create learning and training opportunities globally for accountants, attorneys, tax practitioners, financial planners, bankers, and other professionals, as well as business executives, in the fields of International Taxation & Offshore Financial Centers.

By applying the case study method to the structuring of international tax plans (that respect the letter and the spirit of the law), the Institute gives to students an incomparable training by any world standards.

It is the mission of the Institute to maintain its position as the world’s principal educational authority in the field of international tax planning.

The Institute, together with Da Vinci, aim to be renowned for the quality of its courses, teaching, and administration, and to create the world’s benchmark training in this highly specialised field.

Objectives and Goals of the Masters Program

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The Masters Program offers training of a world-class nature in the multi-billion dollar industry of international tax planning and offshore financial centers, without the geographical and professional limitations affecting many national professional qualifications.

The Program is specifically designed:• to equip the student to deal with all aspects of international tax planning and

offshore structuring• to give the student hands-on knowledge of correct procedures in dealing with

offshore operations which account for more than half of the world’s international transactions measured in money

• to ensure that the student achieves practical, as well as theoretical, mastery over this complex discipline.

Background Information on Executive ProgramsThe Institute of Advanced Studies has been engaged in offering courses on International Taxation & Offshore Financial Centers since 1980, teaching many thousands of professionals and business executives, as well as Revenue officials, throughout the world.

Venues include:Amsterdam • Atlanta • Baltimore • Boston • Brussels • Cape Town • Chicago • Dallas • Denver • Durban • Edinburgh • Frankfurt • Geneva • Hong Kong • Houston • Johannesburg • Kuala Lumpur • Lisbon • London • Los Angeles • Madrid • Manchester • Melbourne • Miami • Milan • Minnesota-St Paul • New Orleans • New York • Oklahoma City • Paris • Perth • Phoenix • Reno • San Francisco • San Diego • Seattle • Singapore • Sydney • Tulsa • Washington • Zurich

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Documents

· Web viewINTERNATIONAL TAXATION & OFFSHORE FINANCIAL CENTERS MASTERS PROGRAM (NQF Level 9) The Institute of Advanced Studies (Pty) Ltd in association with The Da Vinci Institute