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 programme leverages UCT’s uncontested geographical advantage as a gateway for global engagement in fiscal matters between the developed and developing worlds.
Graduates from the UCT International Taxation Master 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 from the UCT International Taxation Masters 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.
The International Taxation Master is a two-year programme.
Over the course of the two years, 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.
Year 1: Coursework and Lecture Schedule
During the first year, 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 of an in-person seminar session every Monday afternoon, and a recording in preparation for the next week’s session will be released each Thursday. 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 in the first year are International Tax I (FTX5034F) and International Tax II (FTX5033S).
International Tax IThe 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 IIIn 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.
AssessmentMixed assessment methods are used for the International Tax I and II courses. These typically take the form of completing written research assignments, either over a long or short period, essay assignments, tax opinions, in-class presentations, timed exams, and usually, the capstone assessment takes the form of a moot court assignment.
The tax moot assignment dealing with an international tax case is usually presented in the second semester, which comprises group work and oral presentation. The programme convenors may also consider the entry of a UCT team in the annual Leuven international tax moot competition co-organised by the IBFD and the University of Leuven, Belgium.
Year 2: Research
In the second year, students perform independent research and draft a minor dissertation on an approved topic under the supervision of a programme convenor.
If practicable, students are allowed to conduct their research away from Cape Town during the second year.
Which degree? MCom specialising in Taxation in the field of International Taxation or LLM specialising in International Taxation?
The UCT International Taxation Masters is an interdisciplinary programme based in legal and commercial science. The coursework component combines these fields and is, therefore, the same for the MCom specialising in Taxation in the field of International Taxation [CM031FTX09] and the LLM specialising in International Taxation [LM003CML14].
The research component of the degree conducted in the second year determines the degree with which a successful student will exit.
At the start of year 2, 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 at the end of year 1, which are used to inform the decision about the choice of degree and allocation of supervisor.
Only approved research proposals may proceed to registration and receive supervision.
Please refer to the Faculty Handbook descriptions for the degree outline and rules applicable to the MCom specialising in Taxation in the field of International Taxation [CM031FTX09] and the LLM specialising in International Taxation [LM003CML14].
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.
Do I qualify?
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 on the application. An entrance exam or interview may be required.
How much will it cost?
Information regarding fees may be found in the Student Fees Handbook.
How do I apply?
Apply online. 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.
By when must I apply?
Applications open in April. We accept applications until 31 October of the year preceding the programme's start.
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 TaxationThe 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.