Certificate in International Taxation of the Banking Sector

Earn a globally recognised certificate in international taxation of the banking sector

    Obtain the required knowledge, skills and understanding of current tax issues to banking activities and financial instruments within an international context that you need to succeed in your career. We will teach you in detail investment banking, capital markets, global markets, asset financing, asset management, private banking and wealth management.

    What will we teach you?

    Our comprehensive course structure will deep dive into:

    • Fundamental tax issues
    • Tax implications of bank operating models and capital funding/allocations
    • Tax implications for banking activities
    • Transaction taxes and withholding taxes
    • Bank levy
    • Client tax reporting
    • The OECD context

     A detailed breakdown of these are:

    I Fundamental tax issues
    A Residence
    B Permanent establishments
    C Beneficial ownership and withholding tax
    D Double tax relief
    E Transfer Pricing and thin capitalisation
    F General Anti-Abuse Rule (GAAR)

    II Tax implications of bank operating models and capital/funding allocations
    A Tax considerations for using different operating models (e.g. representative offices, branches, subsidiaries)
    B OECD guidelines for attribution of profits to branches, with specific reference to the guidelines for banking and financial trading business, and related bank internal derivatives
    C Tax considerations for the treatment of different types of capital instrument, e.g. Common Equity Tier One, Alternative Tier One, Tier Two, and hybrid capital
    D Attribution of capital to banking branches

    III Tax implications for banking activities
    A Global developments in banking taxation code of conduct and tax transparency; UK Code of Conduct for Banks; Australian Tax Transparency Code for Large Businesses
    B Cross-border tax considerations when loan assets are originated, transferred between entities or branches within a banking group, restructured (e.g. non-performing loans). Tax considerations for the change of domicile by borrowers, or the cross-border sale of loan assets between creditors
    C LMA documentation and tax clauses. Sub-participation and risk sharing within a banking group. Intra- group guarantees
    D Securitisation of assets (e.g. UK securitisation company regime)
    E Tax representations in ISDA Master Agreement
    F Cross-border tax considerations when functions are moved between branches/entities within a banking group

    IV Transaction taxes and withholding taxes
    A Proposed European Financial Transaction Tax; extra-territorial impact of Italian Financial Transaction Tax and French Financial Transaction Tax
    B Application of Stamp Duty and SDRT to on and off-exchange securities transactions in London and Hong Kong markets
    C Withholding Tax on distributions and capital gains for fixed income, cash equities, listed and OTC derivatives, ETNs & ETFs, cash and non-cash collateral, repo and Reverse-repo, stock lending and borrowing
    D US Chapter 3 Withholding on Non-Resident Aliens including IRS Qualified Intermediary Agreement and Qualified Derivative Dealer regime
    E VAT/GST, including partial exemption
    F Cryptocurrency, initial coin offering, asset tokenisation and the secondary market

    V Bank levy
    A UK bank levy
    B Overview of bank levies in other significant territories (France, Germany, South Korea)

    VI Client tax reporting
    A FATCA; Common Reporting Standard (CRS); Directive Administrative Co-operation – 2011/16/EU (DAC2 – 2014/107/EU)
    B UK Corporate Criminal Offences for failing to prevent criminal facilitation of tax evasion (Criminal Finances Act 2017, Part 3); Mandatory Disclosure Regime – 2011/16/EU (DAC6 – 2018/822/EU); OECD, Model Mandatory Disclosure Rules for CRS Avoidance and Opaque Offshore Structures

    VII The OECD context
    A The OECD’s Base Erosion and Profit Shifting (BEPS) Project




    Diagram explaining the Banking syllabus breakdown as follows: Transaction taxes and withholding taxes - 20%. Tax implications of operating models and capital allowance - 20%. Tax implications for banking activities - 20%. Client tax reporting - 20%. Fundamental tax issues - 10%. Bank levy - 5%. The OECD context - 5%.



    Who is it for?

    This study plan is aimed at international tax professionals working across the financial service sector.

    Students may also subsequently embark on sitting for the banking module of the Advanced Diploma in International Taxation ('ADIT'), which is suitable for senior level professionals, managers or those working towards a senior level.

    Our study packages lend students the flexibility to study with us from all over the world with the qualification being pursued in over 110 countries including countries across the GCC region in the Middle East (United Arab Emirates, Qatar, Kuwait, Saudi Arabia, Oman and Bahrain) and North Africa region (Algeria, Egypt, Libya, Morocco, Sudan, Tunisia, Western Sahara).