Advanced Certificate in Taxation is structured for those who are keen to learn technical concepts in local and international taxation. The certificate covers three key aspects of taxation ie., Direct Taxes, Indirect Taxes, and International Taxation. It focuses on technical concepts of direct and indirect taxes and develops an understanding of various components involved in the determination of income tax while dealing internationally. For Secondary jurisdictions GCC, UK, Canada & USA are available on choice, however, a student may select any other tax jurisdiction with the prior approval of the Students Members Committee.

Learning Objectives

ACIT deals primarily with the two areas, i.e. local tax and international tax, and serves to achieve three objectives:

  1. to provide students with a
    working knowledge of the fundamental tax principles and rules that apply to
    commonly encountered transactions undertaken by companies and individuals  
  2. to instil an awareness in
    students that taxes can and often do constitute significant costs to businesses
    and households and therefore can have a major impact in economic and other
    decision-making, but that these costs are also potentially controllable through
    legitimate tax minimisation strategies and
  3. to enable students to appreciate
    the national and international economic, social, administrative-compliance and
    political contexts within which taxes are imposed

Traditional tax courses overly emphasise the first objective, i.e.
compliance with tax laws after the relevant transaction or event has occurred.
It is, however, important for a value-added course in taxation like this one to
address other issues beyond the compliance aspect. Students need to understand
the reasons why, in the first place, the tax law and practice is the way it is
in order for them to fully appreciate the subject. Furthermore, the course
needs to be purposive in equipping students with the ability to identify
relevant and significant tax issues given a proposed transaction or set of
transactions, and to recommend appropriate actions that businesses and
households can take in structuring their transactions and affairs to
legitimately avoid or mitigate their tax exposure.

Learning Outcomes

Today’s business environment has generated
an immense demand for tax experts. Tax profession offers a dynamic and
challenging career in today’s society. In order to adapt the rapidly changing
scenario Tax Professionals are required in every phase of public accounting,
business, and government.

ACIT is a six-month program that covers technical concepts of tax laws in Pakistan, coupled with their relevance to every transaction in today’s challenging business environment of boundary less e-commerce. A special focus is put in learning international taxation to develop an approach of dealing with other jurisdictions and understanding tax impacts of foreign trade.

Eligibility Criteria

Bachelor degree (14 Years of Education) in relevant discipline or equivalent

Syllabus

Paper 1 – Direct Taxes (Technical Concepts)

This paper is to develop technical knowledge relating to Pakistan
Direct Tax Laws and Systems as applicable to individuals, unincorporated
businesses and companies.

This
paper will be examined through short structured questions over the duration of
3 hours and 15 minutes.

  • Income Tax
    1. Income Tax Ordinance 2001
    2. Notifications, Rules, General Orders and Circulars issued under the Income Tax Ordinance 2001 excluding international taxation

  • Provincial Taxes
    1. Property Taxes
    2. Agriculture Income Tax
    3. Other Provincial Taxes (Board of Revenue Taxes, Local Govt Tax and Cesses etc.)
    4. Excise and Taxation

  • Others
    1. Anti-money Laundering Act 2010
    2. Benami Act 2017
    3. Rules and regulations issued under above laws

Note:
Professional ethics and values will be examined as an integral part of each
section with emphasis on:

  • Principle of fair tax legislation and
    tax administration

     

    • Ethics for tax payers and tax advisers
    • Tax evasion, avoidance and
      minimization

Paper 2 –
Indirect Taxes (Technical Concepts)

This paper is to develop technical knowledge relating to Pakistan’s Indirect Tax Laws and System.

This paper will be examined through short structured questions over
the duration of 3 hours and 15 minutes.

  • Sales Tax
    1. Sales Tax Act 1990
    2. Provincial Sales Tax
    3. Islamabad Capital Territory (Tax on Services) Ordinance 2001
    4. Notifications, Rules, General Orders and Circulars issued under the Sales Tax Act 1990

  • Federal Excise
    1. The Federal Excise Act 2005 (Chapters I and II only)
    2. Notifications, Rules, General Orders, and Circulars issued under the Federal Excise Act 2005 relevant to Chapters I and II only

  • Customs
    1. Customs Act 1969 as amended up-to-date (Chapters I, V and VI only)
    2. Details of procedure in relation to levy, collection and exemption from and repayment of customs duties and duty drawbacks

Note: Professional ethics and values
will be examined as an integral part of each section with emphasis on:

  • Principle of fair tax legislation and tax administration
    • Ethics for taxpayers and tax advisers
    • Tax evasion, avoidance, and minimization

 

Paper 3 - International Taxation

Section – A (Principles of International Taxation)

This section is not country specific and focuses on key issues of global taxation such as principles of international tax law, residence, double taxation and treaty interpretation, transfer pricing, the work of OECD and international tax avoidance of direct and indirect taxes.

  1. Basic principles of International Tax Law
  • An Overview of International Taxation
  1. What is International Taxation?
  2. International Tax Conflict and Double Taxation
  3. Double Tax Treaties
  4. Domestic Tax System
  5. International Offshore Financial Centers
  6. Anti-avoidance Measures
  7. International Tax Planning
  8. Non-Resident Taxation in Pakistan
  • Principle of International Taxation
  1. International Tax Law
  2. Application of Tax Treaties
  3. Interpretation of Tax Treaties
  4. Some Legal Decisions on Treaty Interpretations
  5. Model Tax Conventions
  6. Multilateral Tax Agreements
  7. European Union
  8. Harmful Tax Competition
  • Model Tax Conventions on Double Tax Avoidance
  1. OECD Model Convention on Income and Capital (OECD MC)
  2. UN Model Convention (UN MC)
  3. US Model Convention (US MC)
  4. Articles in the Model Conventions
  5. Bilateral Tax Treaties
  • Impact of Domestic Tax Systems
  1. Introduction
  2. Tax Residence or Fiscal Domicile
  3. Source of Income or Gain
  4. Basis of Tax Computation
  5. Treatment of Tax Losses
  6. Advance Tax Rulings
  7. Passive Income
  8. Foreign Tax Relief

2. Transfer Pricing and Thin Capitalization Rules

  1. Introduction
  2. what are Transfer pricing issues?
  3. What is Transfer Pricing?
  4. Meaning of the term “arm’s length Principle”
  5. Significance of arm’s length principle
  6. Practical difficulties in application of ALP
  7. Evolution of Transfer Pricing
  8. Computation of income from transaction with non-resident
  9. Associated Enterprises
  10. International Transaction
  11. Specified domestic transactions
  12. Computation of Arm’s length price
  13. Functions, assets and risk (Far Analysis)
  14. Concepts of Comparability adjustments
  15. Documentation and Compliances
  16. Specific reporting requirements- Country by Country reporting
  17. Transfer Pricing Assessments
  18. Transfer of Income to Non- residents
  19. Introduction of specific anti avoidance measures in respect of transactions with person located in notified jurisdictional area
  20.  Limitation of interest deduction in certain cases

3. International Tax Avoidance

  1. Base erosin and profit shifting
  • Background
  • Overview of BEPS
  • Addressing the tax challenges of the digital economy
  • Neutralise the effects of hybrid mismatch arrangements
  • Strengthen controlled foreign companies (CFC) Rules
  • Interest deductions and other financial payments
  • Counter harmful tax practices
  • Preventing treaty abuse
  • Prevent the artificial avoidance of permanent establishments (PE) status
  • Transfer pricing outcomes in line with value creation/intangibles/risk and capital and other high-risk transactions
  • Measuring and monitoring BEPS
  • Disclosure of aggressive tax planning arrangements
  • Re-examine transfer pricing documentation
  • Making dispute resolution more effective
  • Developing a multilateral instrument

2. Other anti-avoidance measures

Section – B (Second Jurisdiction Taxation)

Candidates are expected to be aware of the key features of the tax system of one of the various tax regimes and be able to answer questions on international tax in relation to a secondary jurisdiction without being expected to offer expert advice on that jurisdiction’s tax system.

Students are expected to have knowledge of the either of the following two aspects of the taxation of the chosen tax jurisdiction:

  1. Income Tax
  • Jurisdiction to tax
  • Taxation of individuals
  • Taxation of companies and other entities
  • Ascertainment of chargeable income and tax liability
  • Tax planning
  • Tax administration
  • Relief from international double taxation

2. Goods and Services Tax

  • The charge to tax
  • Scope of charge: supply; consideration; taxable person; in the course of furtherance
    of business
  • Value of supply and time of supply
  • Ascertainment of tax liability
  • International services and taxation of the digital economy
  • Business-to-business supplies of imported services under the reverse charge mechanism regime
  • Business-to-consumer supplies made to non-GST registered persons
  • Anti-avoidance
  • Tax planning
  • Tax administration

Candidates have to write a thesis on section B

 Thesis

Candidates are required to write a research thesis for section B of papers of Professional Level (after attending advanced research methodology webinar) consisting of 6,000 to 7,500 words on any topic from section B of Paper 3 of Professional Level. Prior approval from the Students and Members Committee is compulsory for writing Research Thesis

 Eligibility: CTA Skills Level passed/referred or equivalent

 Exemptions

A candidate may be eligible to apply for exemptions from some of the CTA examinations if he holds certain recognized educational qualifications. The candidate can only apply for exemptions using educational qualification where he has become fully exam qualified, meaning the candidate has completed all of the necessary examinations for the relevant academic qualification or a mapped level of professional qualification.