DECEMBER 2026 BATCH: Principles of International Taxation for ADIT, UK
About Course
The Principles of International Taxation course for the Advanced Diploma in International Taxation (ADIT) is designed to provide participants with a comprehensive understanding of the fundamental concepts, principles, and frameworks governing international taxation. The course will delve into the complexities of cross-border transactions, tax planning strategies, and the global tax landscape, equipping students with the knowledge and skills necessary to navigate the intricate world of international tax.
Note: Enrollment cannot be canceled or refunded.
Instructor Information
Sanjay Ramanujam is a Fellow Chartered Accountant, CGMA, CPA(US).LLB with three decades of experience across Big 4 firms and multinational organisations, specialising in taxation, finance, and global regulatory frameworks.
He has led major due-diligence, valuation, corporate finance, and restructuring engagements in India and the Middle East, bringing deep real-world insight to international tax learning.
As a seasoned faculty member for professional qualifications like ADIT, CIMA, ACCA, and CA, he is known for simplifying complex concepts and delivering highly practical, exam-focused training.
His global exposure, strong technical grounding, and coaching experience make his ADIT sessions engaging, structured, and aligned with what candidates need to clear the exams with confidence. He is committed to helping learners build strong international tax capabilities through clear explanations, real-life examples, and personalised guidance.
Course Content
Legal Basis
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Recorded Class
00:00 -
Notes
Interpretation of MTC & Scope
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Recorded Class 1
00:00 -
Recorded Class 2
00:00 -
Notes
Resident Article
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Recorded Class 1
00:00 -
Recorded Class 2
00:00 -
Notes
Article 5 PE
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Recorded Class 1
00:00 -
Recorded Class 2
00:00 -
Notes
UN vs OECD and BEPS
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Recorded Class
00:00 -
Notes
BEPS
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BEPS
00:00 -
Notes
Transfer Pricing
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Recorded Class
00:00 -
Notes
Article 24 Non Discrimination
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Recorded Class
00:00 -
Notes
Multilateral Instruments
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Recorded Class
00:00 -
Notes
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Limitations of MLI Oct 2025
Income from Properties (Articles 6, 13)
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Recorded Class
00:00 -
Notes
Class Recordings
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00:00
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Live Session 1 – 5 September 2026
00:00 -
Live Session 2 – 12 September 2026
00:00 -
Live Session 3 – 19 September 2026
00:00 -
Live Session 4 – 26 September 2026
00:00
Permitted Materials
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OECD Model Tax Convention
00:00 -
UN Model Double Taxation Convention
00:00 -
BEPS Report 2018 – Executive Summary
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OECD TP guidelines on Multinational Enterprises and Tax Administrations
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Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS
00:00 -
Action 7 – Additional Guidance on Attribution of Profits to PE
00:00 -
Report on the Attribution of Profits to Permanent
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Consolidated Report on Amount B
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United Nations Vienna Convention on the Law
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Agreement on Exchange
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OECD Standard for Automatic Exchange of Financial
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OECD Report on the Attribution of Profits to Permanent
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Multilateral Convention to Implement Amount A of Pillar One
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MLI STTR Booklet
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OECD Convention on Mutual Administrative Assistance
Library
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ADIT Syllabus
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Use of OECD commentary Interpretation
00:00 -
Brian J Arnold Tax Treaties
00:00 -
PIT Text
00:00 -
Action Statement 7 – Artificial Avoidance of PE
00:00 -
Note on Force of Attraction vis a vis PE
00:00 -
FAQ on MLI
00:00 -
BEPS 7 Summary of Final Report Items EY
00:00 -
Myths and Facts about BEPS
00:00 -
Action Statement 1 Challenges of Digital Economy
00:00 -
Action Statement 4
00:00 -
Transfer Pricing Guidance on Financial Transactions Inclusive Framework on BEPS Actions 4 8 10
00:00 -
Action 2 Hybrid Mismatches
00:00 -
Action Statement 6 Preventing Tax Treaty Override
00:00 -
Action 5 Resumption of Application of Substantial Activities Factor
00:00 -
Action Statement 5
00:00 -
Bold International Tax Reforms to counter GLoBE
00:00 -
OECD Amount B guidelines
00:00 -
Achievements of BEPS
00:00 -
Action 3 CFCs
00:00 -
Action Statement 14 Dispute Resolution More Effective
00:00 -
Action Statement 15
00:00 -
Action 12 Mandatory Disclosure
00:00 -
OECD Automatic Exchange of Information Report
00:00 -
Model Mandatory Disclosure Rules for CRS Avoidance Arrangements and Opaque Offshore Structures
00:00 -
CRS Publication
00:00 -
Article 26 Amendment Feb 2024
00:00 -
Action 8 10 Aligning Transfer Pricing Outcomes
00:00 -
Action 13 – Country by Country Reporting
00:00 -
Progress Report on 7 Principles for Global Tax Cooperation
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Mar 24 Tax Treaty Misuse Progress Report
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Case Law on Virtual PE
00:00 -
Article 3
00:00 -
Article 4
00:00 -
Outcome Statement on the Two Pillar Solution
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Statement on a Two Pillar Solution to Address the Tax Challenges Arising from the Digitalization of the Economy October 2021
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Important Questions
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Amount A Pillar 1 Whether a Solution
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Multilateral Instrument BEPS Tax Treaty Information Brochure
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Multilateral Instruments – Is it a Game Changer for India 1
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EY Worldwide Transfer Pricing Reference Guide 2025
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European Union OECD_The Interaction Between Directives and Tax Treaties Three Case Studies
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IMPORTANT CHANGES – OECD MTC Nov 25 Amendments
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IMPORTANT CHANGES – OECD Model Tax Convention 2025 Update Key Changes
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UN Tax Reforms – Conceptual Note
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OECD Implementation Report to G20
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Progress Report on 7 Principles for Global Tax Cooperation
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UN vs OECD Principles
Question Papers
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December 2019
00:00 -
December 2020
00:00 -
June 2021
00:00 -
December 2021
00:00 -
June 2022
00:00 -
December 2022
00:00 -
June 2023
00:00 -
December 2023
00:00 -
June 2024
00:00 -
December 2024
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June 2025
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December 2025
Assignments
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Assignment 1
Important for June 2026 Examination
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Dispute Resolution Statistics Progress Report 2024
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Note on ICAP Feb 2026
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Note on Impact of BEPS Implementation April 2026
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Case Citations for PIT
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MFN Clause ITCD article