Advanced application of Ghanaian tax law — complex corporate and personal tax issues, international taxation principles, tax planning, and advising clients on tax-efficient structures.
Builds on: 2.6 Principles of Taxation
Advanced Taxation demands the highest level of tax knowledge and application in the ICAG qualification. Candidates must advise complex clients — multinational groups, high-net-worth individuals, businesses restructuring or merging — on the most tax-efficient legal strategies available under Ghanaian and international tax law. The paper integrates transfer pricing, double tax treaties, anti-avoidance legislation, and ethical tax practice. Answers must be written as professional advisory communications, not just calculation answers.
Groups of companies, associated companies, close companies, and the interaction of multiple taxes.
Residence, source, permanent establishments, Ghana's tax treaties, and the OECD model convention.
Arm's length principle, transfer pricing methods (CUP, resale, cost-plus), documentation requirements, and OECD guidelines.
Legitimate tax planning, the boundary with evasion, GAAR (General Anti-Avoidance Rules), and ethics of tax planning.
Tax implications of business succession, gifts, inheritance, and restructuring for family-owned businesses.
GRA investigations, objection procedures, the Tax Appeals Board, and alternative dispute resolution.
Tax advice must always be balanced — identify the tax-efficient option AND flag any risks, anti-avoidance implications, or ethical concerns. Candidates who present one-sided advice are penalised at Level 3.
Tax Partner / Manager
International Tax Specialist
Transfer Pricing Adviser
In-house Tax Director
Big 4 Tax Consultant
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