About the programme 

The University of Cape Town presents Africa’s first and one of the only interdisciplinary programmes fully dedicated to the study of international taxation.  The programme is co-presented and taught by UCT’s Faculties of Commerce and Law in cooperation with the International Bureau of Fiscal Documentation (IBFD).

The International Taxation Master's programme leverages UCT’s uncontested geographical advantage as a gateway for global engagement in fiscal matters between the developed and developing worlds. 

Career Prospects

Graduates from the UCT International Taxation Master's programme are sought after and have excellent career prospects, both in South Africa and elsewhere. The principled knowledge, analytical skill and way of thinking gained from the programme is highly flexible in its application in a variety of professional career settings, including in advisory, law, accountancy, fiscal regulation, academia, and in-house expertise.

Past graduates occupy positions such as International Tax Advisor, Consultant, Manager, Lawyer, Tax Director, Director, Group Tax Manager and Senior Lecturer within international accounting firms, boutique specialist international tax practices, leading local and international law firms, multinational corporates, universities, and government agencies including revenue authorities and Ministries of Finance.

Programme Outline

The International Taxation Master's is either a one-year or a two-year programme.

Over the course of the registration period, students have unrestricted access to the IBFD online research platform, the Kluwer International Tax Database, the International Tax Law Reports and an impressive array of resources from all UCT libraries, including a large and up-to-date monograph collection.

Degree Routes

The UCT International Taxation Master's is an interdisciplinary programme based in legal and commercial science. There are three routes to obtaining the degree.

1-year Degree Route

• Master of Laws in Tax Law specialising in International Taxation [LM026CML14] (Professional Master's degree)

This is a one-year, full-time professional qualification (180 NQF level 9 credits), combining compulsory courses and research tasks that reflect real-world legal practice. The courses are International Tax I and International Tax II.

Unlike traditional LLMs, this programme does not include a minor dissertation. Instead, the research tasks are practice-based, such as drafting tax opinions, writing reports, or participating in moot court assignments. They are completed concurrently with coursework over each semester, based on set tasks and topics, and have fixed hand-in deadlines.

LLM (Professional): 180 credits comprising 2 courses of 60 credits each and 2 professional research tasks of 30 credits each.

2-year Degree Routes

• Master of Commerce specialising in Taxation in the field of International Taxation [CM031FTX09]
• Master of Laws specialising in International Taxation [LM003CML14]

This is a two-year programme (240 NQF level 9 credits) following the traditional structure of a LLM degree in South Africa. The courses in the first year are International Tax I and International Tax II.

In the second year, students focus on the research component by performing independent research and drafting a minor dissertation on an approved topic under the supervision of a UCT academic. At the start of the year, students need to make a choice whether they wish to complete a minor dissertation in law or commerce. Background and experience are important considerations in deciding which degree to pursue. Furthermore, research proposals are required to be presented, which are used to inform the decision about the choice of degree and the allocation of a supervisor. Only approved research proposals may proceed to registration and receive supervision. If practicable, students are allowed to conduct their research away from Cape Town during the second year.

LLM/MCom (coursework & dissertation): 240 credits (LLM) or 180 credits (MCom) comprising 2 courses of 60 credits each, and a dissertation of 120 credits (LLM) or 60 credits (MCom).

The coursework component combines the fields of legal and commercial science and is, therefore, the same for the three degree options.

Coursework and Lecture Schedule

During year one, over two semesters from February to May and July to November, residential-based courses are presented in Cape Town.

In the first week, the IBFD will present an intensive overview of international taxation and the tax treaties. Thereafter, the following weeks will comprise an in-person seminar session every Monday afternoon, and a recording in preparation for the next week’s session will be released a week in advance. The IBFD intensive week and weekly seminars are in-person, and attendance is compulsory.

Teaching takes the form of lectures or seminars, consisting of guided group discussions with a focus on case studies applied in a practical manner, as well as theoretical engagement with the legal architecture of the international tax regime and its underlying norms. Advanced digital learning platforms are used to assist with lecture preparation and study.

All teaching is undertaken by UCT academics with a legal and/or commercial background, by leading practitioners or by international guests. The list of teaching faculty may be viewed here.   

The courses are International Tax I (FTX5034F) and International Tax II (FTX5033S).

• International Tax I

  The first semester commences with an intensive week of residential lectures presented by UCT academics and visiting staff from the IBFD. The problem of double taxation and the solutions offered by double tax conventions are introduced. Additionally, topical areas may be covered. Past topics included taxation of the digitised economy, international tax transparency, the role of the BRICS in international tax policy, and Base Erosion and Profit Shifting.
  
  Following an intensive first week of block lectures facilitated by IBFD staff, for the remainder of the first semester, weekly seminars cover aspects of double tax conventions in detail. Consideration is given to the OECD, UN and ATAF Model Tax Conventions, the history of the international tax system, treaty provisions dealing with business taxation, investment flows, and income of individuals, as well as more complex areas such as legal methods of treaty interpretation and key features of South Africa’s double tax treaty network.
  
  Teaching takes the form of seminar discussions for which students are expected to prepare. A significant workload can be expected.

• International Tax II

  In the second semester, weekly seminars shift to more specialised topics under double tax conventions and other international fiscal instruments.
  
  Topics dealt with include cross-border tax aspects of immovable property and gains, international shipping, non-discrimination, taxpayer information exchange, double tax relief, dispute resolution under tax treaties, the history of international tax avoidance and legal and other measures aimed to address it, specialist tax treaty clauses and recent international tax developments.
  
  The theory and practice of transfer pricing are taught, usually by an international visiting academic and leading practitioners, during a block period.
  
  Other topics covered during this semester include seminars on taxation and human rights and selected aspects of South Africa’s international tax regime, such as provisions for relief of double taxation and controlled foreign company rules. In addition, international aspects of Value Added Tax are dealt with.

• Methods of Assessment: International Tax I and II

  Mixed assessment methods are used for the International Tax I and II (FTX5034F and FTX5033S) courses. These typically take the form of completing written assignments, either over a long or short period, in-class presentations, and/or reading tasks. The major method of assessment for the courses is timed, invigilated exams.

Assessment

FTX5034F and FTX5033S: A student must achieve at least 50% weighted across all assessments. Oral assessments may be substituted at the discretion of the convener for any of the written assessments. A sub-minimum of 50% must be achieved for the minor dissertation (FTX5032W or CML5694W) on an international taxation topic, and the overall weighted average programme result must be equal to or exceed 50%.

Courses may not be repeated. No supplementary examinations are permitted. Satisfactory progress for research as per the MoU (Memorandum of Understanding.

Please refer to the Faculty Handbook descriptions for the degree outline and rules applicable to each programme.

Apply online. Applications close on 31 October. The programme code is CM031FTX09.

Please note: For administrative purposes, in the first year, all students are registered against the Commerce Faculty programme: programme code CM031FTX09.

The provisional course fees are listed in the Fees Handbook.

Application

Apply online. Applications close on 31 October. The programme code is CM031FTX09 for both of the 2-year degrees and LM026CML14 for the 1-year professional master's route.

Please note: For administrative purposes, in the first year, all students are registered against the Commerce Faculty programme: programme code CM031FTX09.

The provisional course fees are listed in the Fees Handbook.

Programme convenors

Faculty of Law: Professor Johann Hattingh

Faculty of Commerce: Dr Alison Futter

Note that to ensure administrative efficiency, in the first year all applications are processed through the Commerce Faculty with the programme code CM031FTX09. Accordingly, registration queries should be directed to the Commerce Faculty and the Department of Finance and Tax (FTX) administrative staff, Mrs Heather Martin.

Entrance requirements

The minimum entrance requirements are:

• NQF level 8 qualification in Taxation; or
• NQF level 8 qualification in Accounting, including taxation courses at that level; or
• NQF level 8 qualification in Law, including taxation courses; or equivalent international qualification.

Professional and/or academic references for all applicants may be requested. A curriculum vitae and academic transcript are required with the application. An entrance exam or interview may be required.

Please refer to the relevant Faculty Handbooks for full information about entrance requirements.

International Alliances

The programme benefits from the following international alliances.

• International Bureau of Fiscal Documentation (IBFD)

  An academic cooperation agreement with the IBFD enables access for UCT staff and students to the IBFD’s most comprehensive tax research database comprising hundreds of books, thousands of journal articles, and other source materials such as tax treaties, information about the tax systems of all countries in the world, and much more. Moreover, senior IBFD staff annually teach on the coursework and participate in public events arranged by the UCT Tax Unit to which students have full access. UCT is the only African university with this level of cooperation in place with the IBFD.
  
  UCT tax students have the opportunity to participate in the annual Leuven international tax moot co-organised by the IBFD as well as the IBFD’s Global Tax Treaty Commentaries Universities Project Competition. UCT student teams won this prestigious competition in 2017 and 2020.
  
  Annually the UCT-IBFD prize may be awarded for the best minor dissertation written by a UCT student on an international tax topic.
  
  For further information, please visit the IBFD website.

• Advanced Diploma in International Taxation (UK) – through the Chartered Institute of Taxation

  The coursework component of the UCT International Tax Masters aids candidates in preparation for the following modules of the Advanced Diploma in International Taxation (ADIT) presented by the UK Chartered Institute of Taxation: Paper I, Principles of International Taxation; Module 3.03 Transfer Pricing Option.
  
  Past graduates have successfully completed the ADIT concurrently with their registration at UCT. The ADIT is presented independently from UCT. You can view more information about the ADIT here.

About the UCT Tax Unit for Fiscal Research

Throughout the two years, students are encouraged to participate in the activities of UCT’s Tax Unit for Fiscal Research and the local activities of the International Fiscal Association.

The Unit is based in the Faculties of Law and Commerce at the University of Cape Town. UCT is Africa’s highest-ranked university and among the top 200 universities in the world.

The Unit is interdisciplinary, being formed by academics with legal and commercial backgrounds. Several large research projects and consultancy work for government bodies and private entities are all undertaken in the Unit.

Academic staff associated with the Unit teach a substantial offering of tax courses across the Faculties of Law and Commerce, as well as organising and participating in conferences, seminars, and public engagements.