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The foundation of the entire ADIT qualification. Based on the OECD Model Tax Convention and the UN Model Double Taxation Convention.
This is the compulsory module for all ADIT candidates. It is the foundation of the entire qualification and must be passed as part of earning ADIT. It can also be sat standalone for a certificate.
The module is based on the OECD Model Tax Convention and the UN Model Double Taxation Convention, with equal emphasis on both.
| 1 | Introduction to International Tax — source vs. residence taxation |
| 2 | The OECD Model Tax Convention — structure and key articles |
| 3 | The UN Model Tax Convention — comparison with OECD Model |
| 4 | Residence — individuals and companies |
| 5 | Permanent Establishments (PE) — definition, attribution of profits |
| 6 | Business Income — Article 7 |
| 7 | Dividends, Interest, Royalties — withholding tax articles |
| 8 | Capital Gains — Article 13 |
| 9 | Employment Income — Article 15 |
| 10 | Treaty Interpretation — Vienna Convention, OECD Commentary |
| 11 | Treaty Abuse and Anti-avoidance — MLI, PPT, LOB clauses |
| 12 | Transfer Pricing Overview — arm's length principle (Article 9) |
| 13 | BEPS — Base Erosion and Profit Shifting (Actions 1–15) |
| 14 | Pillar One — Amount A, reallocation of taxing rights |
| 15 | Pillar Two — Global Minimum Tax (GloBE rules, 15% floor) |
| 16 | International Tax Avoidance — GAAR, CFCs, hybrids |
| 17 | Exchange of Information — AEOI, CRS, FATCA |
| 18 | Dispute Resolution — MAP, arbitration |
Students must bring these physical books to the open-book exam:
Prof. Bill Cobby Impriam
"Bill is one of the few practitioners in Ghana holding the ADIT qualification. He connects global standards directly into the African and Ghanaian tax reality — something no standard textbook can teach."