CHARTERED INSTITUTE OF TAXATION

(GHANA)

Examination Scheme and Syllabus

August, 2011

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 Our Vision

To be the premier international professional body of choice

Our Mission
To promote the advancement of taxation practice through excellence, integrity and
transparency whilst diligently offering the best professional service to the state and the
public

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 Our Objectives

1. To deal with all matters concerning taxation and take such action with respect thereto
as may be considered expedient.

2. To promote the study of the administration and practice of taxation and the principles
of economic and political science in relation to taxation and public finance in
connection therewith.

3. To hold examinations and to grant certificates to persons who have satisfied the
examiners and the Council of the Institute as to their knowledge of and ability in the
subject of taxation.

4. To facilitate the exchange of information and views on taxation and the creation of a
well-informed public opinion on the subject.

5. To provide opportunities for the acquisition and dissemination of useful information

concerning taxation and, in particular, to sponsor research into taxation as well as
publishing or assisting in the publication of the proceedings of the Institute and of
books, articles and papers on the subject of taxation.

6. To ensure that high standards of professional etiquette and practice are maintained
among members of the Institute.

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STUDENT REGISTRATION

In order to be registered as a student for the professional examinations of the Institute one must
be at least 18 years old and have the following minimum academic qualifications.

1. A first degree from a recognized tertiary institution

2. Taxation Technician Certificate of the Institute
3. Higher National Diploma from a recognized tertiary institution
4. Basic Professional Certificate in Taxation of the Ghana Revenue Authority
5. Any other qualification, in the opinion of the Council, is equivalent to any of the above

Students have ten years to complete the final examinations of the Institute from the date of
their registration as a student.

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THE STRUCTURE OF THE EXAMINATION
The Institute’s professional examinations syllabus is examined at 3 Levels i.e. Professional
Level, Final 1 and Final 2. Students may attempt any number of papers in the Professional
Level and Final Level 1. However, the Professional Level must be completed or exemption
obtained before the Final Level 1 is attempted and the Final Level 1 must be completed or
exemption obtained before the Final Level 2 is attempted.

All the 3 papers at the Final Level 2 must be sat and passed at the same examination session. A
student may, however, be referred in one paper at the Final Level 2 if he obtains a minimum of
40% in that paper and passes the other two papers.

Pass mark for every paper is 50%.

Professional Level
This level consists of:

1. Public Sector Economics and Finance

2. Income Taxation
3. Accounting and Finance
4. Indirect Taxation
5. Revenue and Business Law
6. Strategy and Governance

At this level the syllabus concentrates mainly on the theories and techniques which underlie
practical issues to be examined at later levels.

Final Level 1
The Final Level 1 consists of:

7. Tax Audit and Investigations

8. Oil, Gas and Other Minerals Taxation
9. International Taxation

This level develops analytical skills and intends to equip the student with knowledge of key
subjects necessary to the Chartered Tax Practitioner.

Final Level 2
The Final Level 2 consists of:
10. Strategic Tax Planning
11. Advanced Taxation Practice
12. Tax Practice Administration & Ethics

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At the final levels students are required to demonstrate not only that they have grasped the
requisite skills, techniques and knowledge, but also, that they can apply them in practical
context.

At these levels the student is to establish proof of competence to practise as a professional

Chartered Tax Practitioner and be able to occupy managerial and strategic positions in
commerce, industry, public sector and public practice.

The Final level 2 is not subjected to exemption, no matter the prior qualification the student
might have acquired.

At the final levels the subjects are structured in such a way that emphasis is given to practical
issues, criticism of current developments in taxation and handling of tax planning and
administration issues. By completing this level, the student should be fully equipped to play
tax advisory role as a top flight professional.

The examination at this level will require candidates to submit answers in the form of
Memorandum, Report, Briefing Paper, Discussion Paper and other forms of business
communication.

The Examination Timetable

The Institute’s professional examinations are held twice a year in February and August. The
examination lasts for 6 days starting from the first Monday of the month.

The examination timetable is as follows:

Levels/Days Monday Tuesday Wednesday Thursday Friday Monday

Professional Paper 1 Paper 2 Paper 3 Paper 4 Paper 5 Paper 6
Final 1 Paper 7 Paper 8 Paper 9
Final 2 Paper 10 Paper 11 Paper 12

Every paper starts at 10:00 am.

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THE SYLLABUS

PROFESSIONAL LEVEL
Paper 1 Public Sector Economics & Finance 9

Paper 2 Income Taxation 11

Paper 3 Accounting & Finance 13

Paper 4 Indirect Taxation 15

Paper 5 Revenue and Business Law 17

Paper 6 Strategy and Governance 19

FINAL LEVEL 1
Paper 7 Tax Audit & Investigations 21

Paper 8 Oil, Gas & Other Minerals Taxation 23

Paper 9 International Taxation 26

LEVEL 3 (FINAL)
Paper 10 Strategic Tax Planning 29

Paper 11 Advanced Taxation Practice 31

Paper 12 Tax Practice Administration & Ethics 33

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PROFESSIONAL LEVEL - PAPER 1

PUBLIC SECTOR ECONOMICS & FINANCE

OBJECTIVE

To test the candidate’s ability to:

a) Understand the principles of government finance, sources of public revenue, objects of

public expenditures, problems of fiscal administration, and application of fiscal policies
in stabilizing the national economy.

b) Apply the principles, concepts, theories and techniques of public sector economics and
finance to current economic as well as financial issues and problems.

THE SYLLABUS

The Role and Size of the Public Sector

Views of Government
The Constitutional Mandate for Public Finance
Welfare Economics: Pareto Optimality and the Efficiency of Competitive Markets
Consumer and Producer Surpluses

Public Expenditure Policy

Causes of Market Failure
Externalities
Public Goods and Private Goods
Resource Allocation Mechanism of Public Goods
Government Failure
Public Choice Theory
Public Expenditure Analysis and Growth

Public Resource Mobilisation

The role of Taxation in the National Economy
Attributes of a Good Tax System
Kinds of Taxes
Major Criteria for a Good Tax Structure

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 Categories of Equity
Tax Incidence Analysis
Theory of Income and Consumption Taxation
Taxation and Work Effort
Taxation, Savings and Risk-Taking
Alternative Sources of Revenue to Government

Tax Policy
Optimal Design of Direct and Indirect Taxation
Tax Evasion and Avoidance
Tax Structure
Tax Reform
Fiscal Policy Analysis
Keynesian Perspective on Fiscal Policy
Fiscal Policy with a Deflationary Gap
Fiscal Policy with an Inflationary Gap
Supply-Side View on Fiscal Policy
Policy Lags

Public Debt Analysis

Domestic Borrowing
Foreign Borrowing/External Indebtedness
Debt Service Capacity
The Debt Burden and Inter-Generational Equity
Effect of Domestic Debt on Capital Formation

Intergovernmental Fiscal Relations

Fiscal Disparity
The Theory of Grants

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PROFESSIONAL LEVEL – PAPER 2

INCOME TAXATION

OBJECTIVE

To test students’ ability to:

a) Understand the principles of income tax
b) Prepare tax returns and compute income taxes
c) Understand the Internal Revenue Act and Regulations and apply them to practical
issues.

THE SYLLABUS

1. Imposition of Tax

The imposition of income tax on the income of resident or non-resident persons

from business, employment and investment accruing in, derived from, brought into
or received in Ghana.

Distinction between chargeable and assessable income. Calculation of chargeable

and assessable income.

Deduction allowed and not allowed. Meaning of “Wholly, exclusively and

necessarily incurred”. Distinction between “Capital expenditure” and “Revenue
expenditure”. Exempt income. Industry concessions. Treatment of losses.
Donations.

Provisional and self-assessments.

Capital allowances, other reliefs.

2. Taxation of Employment Income

The definition of employment income. Primary, consecutive primary and

secondary employments.

Tax reliefs; tax relief cards. Substantiated retirement contributions. Returns by

employer. Deemed employee assessments. Returns of income of individual with
two or more employments.

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 Withholding of tax by employers; PAYE System; Calculation of employee’s
employment tax liability.
The meaning and treatment of qualifying cash payments. Perquisites of office.
The treatment of retirement fund savings and contribution to a retirement fund..

3. Taxation of Individuals, Partnerships and Partners

Principle of taxation for individuals, partnerships and partners

Ascertainment and computation of chargeable and assessable income
Reliefs and reductions. Capital allowances
Partnership obligations
Reduction of income for life insurance premiums paid.

4. Taxation of Companies, Shareholders, Bodies of Persons and Owners

Principles of taxation for companies

Ascertainment and computation of chargeable and assessable income
Taxation of insurance companies; short-term insurance business; reserve for
unexpired risks; rules relating to Life Insurance business.
Introduction to taxation of petroleum and mining companies
Taxation of all other companies such as banks, non-banking financial
institutions, manufacturing companies, trading companies and other service
companies
Capital allowances and rules relating to leases. Other reliefs.

5. Taxation of Capital Gain

The definition, ascertainment and computation of capital gain

The meaning of cost base
Realization of asset; chargeable asset
Exemptions from capital gain tax
Computation of capital gain tax.

6. Taxation of Gifts
The definition and ascertainment of taxable gifts
The valuation of taxable gifts
Computation of gift tax
Exemptions from gift tax.

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PROFESSIONAL LEVEL – PAPER 3

ACCOUNTING & FINANCE

OBJECTIVE

To test the candidate’s ability to:

a) Apply accounting principles, concepts and techniques to financial accounting practices

b) Prepare and interpret financial accounting reports and apply the principles of taxation to
them

c) Understand the significance and limitations of the financial statements and their tax
implications

d) Manage financial resources and appraise investment opportunities of an organization.

THE SYLLABUS

1. Preparation of financial statements for

Partnerships including
- Amalgamation of firms
- Dissolution of partnerships
- Admission of a new partner and the consequences of death of a partner
- Conversion of partnership into Limited Liability Company

Limited liability companies within the companies code and the regulatory frameworks
including
- Simple consolidated accounts of group of companies
- Joint ventures
- Associated businesses

2. Interpretation of financial statements

- Identification of users of financial statements and be conversant with the uses of the
information within
- Objectives of financial statements
- Analyse and interpret financial statements by ratio analysis or other methods for
performance.

3. Valuation of business and income measurement

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- The preparation and presentation of accounts and reports relating to offer for sale,
rights issue and profit forecast
- Methods of valuing the whole undertaking; majority and minority holdings as a going
concern, for purposes of a merger; or total or partial liquidation
- The theory of accounting in relation to income measurement; capital maintenance
- Problems of profit measurement and alternative approaches.

4. Accounting for specialized transactions

- Hire purchase and Leases
- Branch accounts
- Foreign currency transactions

5. Financial Management
- The nature, purpose, and scope of financial management.
- Sources of finance. Equity and Debt Finance; Venture Capital; Capital Markets; Issue
of Shares; Rights Issues; Bonus Issues; Reduction of Capital. Stock Market Ratios and
Stock Market Analysis
- Gearing: Impact of gearing on business. Relevance of gearing to investors
- Working Capital management. Main components of working capital; Methods for the
control of investment in cash, trade debtors and stock
- Investment Appraisal. Appraising techniques; Lease or buy decisions. Sale and
leaseback decisions
- The effect of taxation and inflation on investment decisions
- Preparation of forecast financial statements and interpret their significance
- Methods of dealing with risks and uncertainties in financial management.

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 PROFESSIONAL LEVEL – PAPER 4

INDIRECT TAXATION

OBJECTIVE

To test the students’ ability to

a) Understand the principles of indirect taxes

b) Prepare tax returns and compute indirect taxes
c) Understand indirect tax laws and regulations and apply them to practical issues.

THE SYLLABUS

Introduction

Sources of indirect taxes to government

The incidence and impact of indirect taxation
Bases of indirect taxation
The principle of ‘no consumption no duty payment’
The principle of ‘payment of duty once on goods’
Determination of quantity in containers, packages and space

Value Added Tax

Jurisdictional Principles of VAT: destination based taxation and origin based taxation
The effects of cross border transactions on taxation of goods and services
Concepts of consumption: determination of place of consumption

Taxable persons and taxable value

Definition of a taxable person
Registration and De-registration of taxable persons
Definition of a taxable value: meaning of consideration
Determination of taxable value for gifts, for own use and for supply of goods
The meaning of tax point: activities that create tax points

Taxable Supply
Definition and concept of taxable supply
Gifts or loans of goods and services
The leasing or letting of goods on hire
Goods for personal use or consumption by the taxable person or any other person
The sale, transfer assignment or licensing of patents, copyrights trademarks, computer software
and other intellectual properties

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Export of non-traditional products
Place of supply rules
Supply of goods and services: Mixed supplies; supply by agents; supply by partnerships;
supplies by members of a group; Taxable supply; Exempt and Zero-rated supplies; relief
supply; time and place of supply rules
Valuation of taxable supply;
The definition of imported service or exported service: tax treatment of imported service; The
Reverse charge mechanism
Concept of consumption: determination of place of consumption

VAT accounting and records

VAT accounting for Input and Output Tax
VAT Refund procedure
Special VAT schemes: computer generated invoice, VAT Relief Purchase order, upfront relief
of import VAT and retail schemes
The tax treatment of Bad debts
VAT accounting for acquisitions and disposals of capital goods
The treatment of Import VAT

Communication Service Tax

Meaning of Communication
Person liable to Communication Service Tax
Computation and tax accounting for communication service tax

Customs, Excise, Duties, Controls and Special Taxes

Export and Import Controls and Regulations
Customs warehousing: bonds and securities; assessment of rent at state and government
warehouse
Methods of delivery of goods
Relief of goods from import duties
Valuation of goods for custom purposes in accordance with World Trade Organisation concept
and Customs Law
Deferment arrangements
Origin rules: Documentary proof of origin
Personal import reliefs
Prohibited and restricted goods
Returned goods
Tariff classification
Preventive controls and regulations
The Postal Traffic: legal basis; authorized post; declaration; parcel post depots; purpose of
custom control; functions and responsibilities of post office officials
Free Zones: definition; types of free zones; controls at free zones
Passengers, Exporters and Importers rights and obligations under Customs Laws and
Regulations
The drawback regime
Excise Manufacturing: the principles of excise control; the excise field; computation and
accounting of Excise on manufacturing; protection of the excise tax; right of access
Smuggling and powers of the custom officers

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PROFESSIONAL LEVEL 1 – PAPER 5

REVENUE AND BUSINESS LAW

OBJECTIVE

To test the students’ ability to:

a) Understand the principles underlying the existence of companies

b) Understand the management, administration and finances of companies
c) Understand the management and administration of partnerships and joint ventures
d) Understand financial laws and their application to practical issues.

THE SYLLABUS

REVENUE LAW
The structure and philosophy of Ghana taxation
Tax policy and tax reform
Tax jurisdictions; international dimension
Income; concepts of income; income from employment, business and capital; statutory
extension to income base; deductions- general and specific deductions-substantiation
Tax avoidance and evasion
Introduction to income taxation
General principles of capital gains tax; rates and payment of tax; exemption and reliefs;

COMPANY LAW
Nature and Types of Companies formed under the code. Formation and Registration:
Regulations; Promoters
Corporate personality; limited and unlimited liability
Corporate entity theory; Doctrines of Ultra Vires and lifting the veil of incorporation
Incorporation procedures and restriction on choice of name
Statutory books, records and returns. Register of shares, charges, directors, and shareholdings.
Pre-incorporation contracts

Equity and Loan Capital

Flotation; Methods of raising capital; Prospectus; Shares; Classification of shares; Class rights;
Transfer, purchase and redemption of shares.
Secured and unsecured tenders; Floating and Fixed Debentures; Priorities
Maintenance and alteration of capital; Dividends

Directors, Secretaries and Auditors

Appointment, qualification, disqualification and removal
Powers of Directors, Secretary and Auditor; Directors and Secretaries as agents

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Duties and rights of directors, secretary and auditor
Limitations upon management to make contracts
Meetings and proceedings at meetings
Division of power between the board of directors and general meetings

Corporate Information
Accounting disclosure requirements and exemptions
Reports and Returns: Role of the Registrar of Companies.

Shareholders
Majority control and the rights of minorities
Role of appointing directors, attending meetings and passing resolutions
Limitation of minority shareholders
Matters requiring shareholders approval

Liquidation and Capital Reorganization

Voluntary and compulsory liquidation
Appointments, rights and duties of liquidators and receivers
Investigation of officers’ conduct: Civil and Criminal remedies
Proof of debt
Protection of investors and creditors
Re-organization: Dissolution; Reconstruction; Amalgamation; Arrangements and Takeovers.

PARTNERSHIP LAW
Nature of partnership
Formation of partnership agreement
Relationship between partnership agreements and rules applicable in the absence of a
partnership agreement
Cessation of membership of firm; Admission of partner (s)
Winding up and dissolution of partnerships
Joint ventures

FINANCIAL LAWS
Banking Law
The requirements for licensing banks; Statutory obligations for operating a bank; The
maintenance of a reserve fund. Provisions in respect of declaration or payment of dividend:
Granting facilities; The Supervisory and Control roles of Bank of Ghana; Objects and the
functions of Bank of Ghana.

Insurance Law
The objects and functions of the National Insurance Commission; Statutory obligation of
Insurers: Registration of insurers, insurance brokers, adjusters, chief agents and agent.
Appeals, suspension and cancellation of registration

Other Financial Law

Non-banking financial law; Security Industry Law; Ghana Stock Exchange Law; Investment
Code

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PROFESSIONAL LEVEL – PAPER 6

STRATEGY AND GOVERNANCE

OBJECTIVE

To test the candidates’ ability to:

a) Explore in broader and specific context the managerial functions and strategic
directions of an organization
b) Understand and appreciate current corporate governance issues and developments.

THE SYLLABUS

1. Strategic Management
- Nature of Strategic decisions. Strategic management process. Mission. Goal.
Objectives
- Strategic Analysis of nations, businesses and organizations. External and
internal analysis. SWOT; PEST; 7Ps; Competitors cost analysis; Generic
Competitive Strategies. Tools for strategic analysis; Structural analysis
(Porter’s forces model); Boston Consulting Group matrix (BCG); Porter’s
Value Chain; Product Life Cycle.
- Strategic Development Routes and achievement of Strategic Fits. Internal and
External growth strategies. No change strategies. International strategies.
Strategies for declining Businesses. Exit Strategies.
- Evaluation of Strategies. Nature of strategic evaluation. Evaluation criteria.
Assessment of the strategic logic of options. Use of BCG Matrix; Life Cycle
analysis; Life Cycle Portfolio Matrix.
- Strategic Plan formulation and implementation. Organizational Culture.
Teams and team management. Strategic change. Change and innovation
management.

2. Strategic Operations and services Management

- Design of Strategic Operation System. Estimation of resources and time to
accomplish work. Cost of services required
- Operation planning and control. Resource allocation. Time management
- Just-in-time techniques
- Total Quality Management; Techniques of quality control and quality
assurance; Quality Circles
- The role and purpose of marketing. Identifying marketing opportunities and
competitive advantage. The impact of globalization on the market and
operations.

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3. Strategic Human Resource Management
- The importance and nature of human resource management
- Human resource planning
- Selection, recruitment and placement
- Performance evaluation. Job evaluation, staff appraisal and performance
measurement
- Formulating an effective compensation mechanism
- Training and developing human resource
- The legal framework of human resource management.

4. Corporate Governance
- The rationale and nature of Corporate Governance
- Composition of the Board of Directors
- Functions of the Board of Directors
- Role of Executive and non-Executive Directors
- Best Practices of Corporate Governance in Ghana and elsewhere, e.g. the King
Report of South Africa, the Combined Code of UK, and OECD Principles
- Board Committees
- The role of shareholders and other stakeholders in the practice of good
corporate governance
- The implementation and reporting of corporate governance policy.
Stakeholders/shareholders expectations; and statutory requirements. Internal
reporting mechanism.
- Controls. Developing and implementing control systems. Nature of Internal
Controls. The purpose and functions of the Internal Audit Act and Financial
Administration Act.
- Ethics and ethical responsibilities of directors. Social responsibility.
Managing ethical behaviour.

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FINAL LEVEL 1 - PAPER 7

TAX AUDIT AND INVESTIGATION

OBJECTIVE

To test students ability to apply auditing and investigation principles and procedures to obtain
information for taxation practice and other purposes

THE SYLLABUS

1. The Framework of Auditing

The concept of accountability; Auditing principles, concepts, methods and

techniques. The concept of independence; the professional and legal environment;
Legal rules; professional guidelines and ethical aspects of auditing.

2. Duties and Responsibilities of the Auditor

The responsibilities of the auditor for misstatements and forming opinions on

financial statements; The auditors’ duties to primary clients and third parties.
Auditors’ liability

3. Audit Planning

Evaluation of the client: Objectives and scope of the audit: Audit risk areas.
Engagement letter; Developing the audit plan to achieve the desired goals. Audit
files and working papers; Work programmes; Job Costing budgets; Audit
committees.

4. Audit Practices and Procedures

Audit evidence collection: Sources and methods of collecting audit evidence.

Selecting the appropriate audit procedures; Audit tests. Compliance and substantive
test; Statistical and other sampling approaches to audit testing; Observation and
directional testing; Cut-off tests; Third Party confirmations; Management
representations; Evaluating internal controls. Systems audits; evaluating the
management information systems; Computer-based systems; Computer assisted
audit techniques

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5. Audit Engagements and Investigations

Tax compliance risk management: desk audit; issue oriented audit; comprehensive
audit; case selection methodologies; data mining; rule based and automated risk
scoring systems; tax returns; information from third parties; previous case histories;
generic taxpayer/business sector profiles; screening or use of data analyzing
techniques for case selection; other statistical analyzing techniques

Terms of Reference; Responsibilities to third parties; Investigation and audit for tax
purposes; Investigation and tax audit under Ghana Revenue Authority legislations.
Investigative Techniques; Leads; Revenue inquiry and investigations; Taxpayer
questionnaires; Information gathering techniques; Determination of customs regime
relating to application of Harmonized Codes; Analysis of financial statements (eg
production records) to determine the reliability of financial and other records for tax
purposes Management Audits

6. Audit Review and Report

Evaluating and analyzing the reliability, relevance and sufficiency of audit evidence;
forming audit opinions. The form and contents of audit reports; Tax audit and
investigation reporting

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FINAL LEVEL 1 - PAPER 8

OIL, GAS AND OTHER MINERALS TAXATION

OBJECTIVE
a. To understand the basic principles, theories and techniques of petroleum economics
b. To be conversant with the regulatory framework of the oil, gas and other minerals
sectors
c. To understand the fiscal regime of the oil, gas and other mineral industry
d. To apply (a.) to (c.) above to solve real time tax problems

THE SYLLABUS

Introduction

Ownership of petroleum resources, minerals; acquisition of petroleum and mineral rights; The
rationale for having unique tax regime for the extractive industry; the aims and objectives of
the state and investors to venture into the extractive industry; the pre-emption right of the
Republic of Ghana; the pre-license phase; reconnaissance phase; prospecting phase; rights
acquisition/contracting phase; exploration phase; evaluation and appraisal phase; development
phase; production phase; decommissioning phase; surrender of mineral rights; suspension and
cancellation of mineral rights, mining lease or restricted mining lease; surface rights and
compensation; power of the Minerals Commission; functions of the Inspectorate of Mines

Fundamentals of Petroleum Economics

Petroleum micro economics: theory of the firm in the petroleum sector; revenue concepts –
cash flow and revenue; cash flow versus profits; fixed costs versus variable cost; marginal
costs; how costs, revenues and profits vary with output

Petroleum macro economics: supply and demand; impact of energy on economic growth; the
effects of fiscal and monetary policy on the petroleum sector; the impacts of international
organizations such as OPEC on the petroleum sector

The regulatory framework of Oil and Gas industry

The role and functions of the national petroleum regulatory authority

The Petroleum Exploration and Production rule and regulations
The Petroleum Agreements: scope and interests of the parties; contract area and period of
exploration; exploration programme; relinquishment; joint management committee; obligations
and right of contracting parties; sharing of crude oil; measurement and pricing of crude oil;
foreign exchange transactions; provisions for natural gas; information and reports; inspection,

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safety and environmental protection; accounting and auditing; title to and control of goods and
equipment; purchasing and procurement; employment and training; force majeure; term and
termination; consultation, arbitration and independent expert assignment; corporate guarantee

The Fiscal Regime of Oil and Gas industry

The Fiscal System: concessionary or royalty or tax system versus production sharing system;
joint venture arrangement; marginal field operation or sole risk; service contract; carried
interest/paying interest; surface rentals; signature bonus; ring fence rules; corporate tax and
other reliefs
Tax-deductible and treatment of all phases of oil and gas operations
Revenue and cost streams: cost oil; profit oil; royalty; petroleum income tax; withholding tax;
additional oil entitlements; upstream versus downstream operations

The Petroleum Holding Fund: payment in lieu of cash; receipts; prohibitions; carried and
participation interests; transparency and accountability of receipts; reconciliation of the fund;
benchmark revenue; annual budget funding amount; disbursement from the fund; transfers into
the consolidated fund

The Ghana Petroleum Fund: management and investment of the fund; reports on the fund; The
Ghana Stabilization Fund; The Ghana Heritage Fund; objects and constituent of the funds;
withdrawals from the funds; composition and functions of the Investment Advisory Committee
Public Interest Accountability Committee: composition; objects and functions

The Fiscal Regime of Other Minerals

The tax treatment of preliminary costs; the tax consequences a company entering into a ‘Farm-
in/Farm-out Agreement’ that allows another company to “earn” an interest in company’s
tenements by incurring exploration costs

The tax consequences of deciding to move on from the exploration and development phase and
commence mining operations

Financing the purchase of equipment by way of lease, rather than loan; determining the
estimated life of a mine and selling, or scrapping (or demolishing) mining plant & equipment;
the relationship between tax and accounting depreciation

Differences between royalties and resource rental tax

The Mining Lease: terms for the granting of the mining lease; change of control; objection to
new or increased control; contraventions by the controller; restrictions and sale of shares;
special share of the Republic of Ghana; government participation in mining lease; programme
for mining operations; Merger and enlargement of mineral rights; Stability agreements;

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Application fee; Annual ground rent; Annual mineral rights fee; The computation of mineral
royalties; Corporate tax computation of mining entities

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FINAL LEVEL 1 - PAPER 9

INTERNATIONAL TAXATION

OBJECTIVE

a. To understand the principles, theories and techniques of international taxation

b. To understand the interaction of the Ghanaian tax system with other tax jurisdictions
c. To apply the principles, theories and techniques of international taxation to practical
situations
d. To solve unstructured problems which draw on the interaction of the Ghanaian tax
system with other tax jurisdictions

THE SYLLABUS

Introduction to international taxation

The definition of international taxation
The evolution of International taxation
The importance of international taxation: policy objectives
Primary and secondary sources of international tax
Primary and secondary rights of countries to charge tax:
Taxing rights of countries and constraints on countries taxing rights
International tax planning and forms of business organizations
The challenges of E-Commerce on international taxation

Jurisdiction to tax
The meaning of residence: ‘in person am’ jurisdiction
Definition of residence in relation to a natural person; the physical presence test
Definition of residence in relation to persons other than natural persons: place of effective
management
‘Trading with’ versus ‘trading in’ a country
Branch versus subsidiary
Residence versus source: residence system; source system; mixed system
Dual residency and changes of residency
Tax havens and the issue of preferential tax regimes

Taxation of non-residents
Taxation of non – residents on domestic source of income (inbound) and on foreign source of
income (outbound)
Taxation of income of non – residents derived from, brought in, accrued in Ghana
Source rules for income and expenditure

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Taxation of business, employment and investment incomes: the concept of permanent
establishment and attribution of profits
Departures: tax claims and exit tax mechanisms
Methods of collecting tax from non – residents
Ring fencing activities for tax purposes

Taxation of International transactions

Globalization, multinationals and tax base allocation
The arms length principle: connected persons; transfer pricing adjustment; elimination of
double taxation: the arms length range
Principles of comparability: factors for the determination of comparables; functional and risk
analysis
Information and documentation: transfer pricing policy; organization structure; nature of
business/industry; market and economic conditions; controlled transactions; transfer pricing
methods applied; assumptions and strategies; cost contribution arrangements; advance price
arrangements
Intra group service; service arrangements; deduction of expenditure paid for intra-group
service
Transfer pricing methodologies: Comparable Uncontrolled Price; Resale Price; Cost Plus;
Profit Split; Transactional Net Margin; Other methods of transfer pricing; Application of
transfer pricing methods
Adjustments to reported income and prevention of double taxation; Adjustment to profit;
corresponding adjustments;
Intellectual Property: patents, trademarks, trade names, designs or models, know-how and trade
secrets, literary and artistic property rights; importance of intangible property; transactions
involving intellectual property; establishing arm’s length royalty; OECD guidance on valuation
of royalty; Transfer of Intellectual Property
Cost Contribution Arrangements and Cost Sharing Arrangements: definition; scope; rationale;
elements; participants; contributions and balancing payments; basis for allocation; ownership
of resulting intangibles
Resolving and avoiding disputes; international tax disputes; origin of transfer pricing disputes;
dispute resolution process; resolving disputes arising from transfer pricing audits; Mutual
Agreement Procedure (MAP)

Thin capitalization or ‘earning stripping’: the arms length concept of thin capitalization; the
aims and objectives of thin capitalization rules; application of the safe harbor ratio; prohibition
of, or restriction on, ‘back to back construction’ in respect of securitization and/or guarantee.

Organisation of Transfer Pricing audit function in revenue establishments: challenges;

centralized versus localised structure

Double taxation
Forms of double taxation: judicial double taxation and economic double taxation
The rationale and objectives of tax treaties
Meaning of ‘person’; ‘company’; ‘enterprise of a Contracting State’; ‘enterprise of the other
Contracting State’; ‘international traffic’; ‘competent authority’; ‘national’; ‘pension fund’;
‘resident of a Contracting State’. Determination of permanent establishment
Taxation of income as per bilateral and multilateral tax conventions

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Methods of preventing double taxation
Consequences of methods of double taxation
Double taxation relief: exemption system and credit system
Tax treaties: OECD Model; United Nations Model; Other Models
Tax treaty shopping; Tax sparing

Other Issues in international taxation

Global challenges and global innovations in international taxation
Labour mobility and income tax competition
Corporate tax competition: the economics of taxing cross border savings income
Money laundering issues: every financial transaction leaves a paper trail
Tax effects in the valuation of multinational corporations
Comparative taxation: different approaches by other jurisdictions to basic principles and
techniques in international taxation
The ethics of tax evasion in international taxation

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FINAL LEVEL 1 - PAPER 10

STRATEGIC TAX PLANNING

OBJECTIVE

To test candidates’ understanding and use of the tax laws in the application and solution to real
time business tax problems

THE SYLLABUS

Strategic Tax Planning

The Decision Making Process

Taxation and Present Value Analysis
Basic Principles of Tax Planning
Entity Variable, Time Period Variable, Jurisdiction Variable, Character Variable
Other Factors Affecting Tax Planning
Legislative and Judicial Restriction, Uncertainty

Tax Strategies for New Business

Organizational Strategies
Organizational Forms for Business Entities
Basic Tax Consequences of Entity Choice
Corporate Formation, Partnership Formation, Single Proprietor Formation
Other Strategies for Transferring Property to Controlled Entities
Sale or Lease of Property to Controlled Entities
Employee Compensation Strategies
Proprietor Compensation, Employee Compensation, Fringe Benefits
Deferred Compensation, Equity Based Compensation, Employee Stock Plans/Options
And Partnership Interest as Payment for Services

Taxation and Business Operating Strategies

Profit Measurements and Reporting

The Entity’s Accounting Year, Tax Accounting Methods
Differences (permanent and temporary) Between Book Profit and Taxable Profit

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Accounting for Income Taxes: Deferred Tax Assets and Liabilities, Corporate Tax Payment
Requirements

Tax Incentive Provisions

Tax Incentives and After-Tax Business Value, Criticisms of Tax Incentives and
Restrictions on their Benefits
Profit and Loss Allocations by Partnership Entities
Partnership Tax Assessment
Distributions to Business Owners
Corporate Distributions, Partnership Distributions, Sole Proprietor Distributions
Anti-Avoidance Schemes

Strategies for Business Growth and Expansion

Multiple-Entity Business Structures

Business Reasons for Multiple Entity Structures
International Business Expansion
Jurisdictional Issues for Multinational Businesses, Double Tax Treaties
Foreign Tax Credit, Sourcing of Income and Deductions, Transfer Pricing

Taxation and Business Capital Transactions

Disposition of Equity Interest in Business Entities

Sales and Exchanges of Corporate Stock, Stock Redemptions, Tax Effects of Stock
Disposition on the Stock Market
Corporate Acquisitions, Mergers and Divisions
Overview of Corporate Acquisitions – Assets or Stock? Purchase of Targets Assets
Limitation on use of Target’s Tax Attributes, Corporate Divisions – Spin-Offs,
Split-Offs and Split-Ups

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FINAL LEVEL 2 - PAPER 11

ADVANCED TAXATION PRACTICE

OBJECTIVE

To test candidates’ ability to:

a) Display an awareness of the impact of all major taxes on transaction of Individuals,
Partnerships and Companies.
b) Appreciate the importance of taxation in personal and business financial planning and
decision making.
c) Solve unstructured problems which draw on the interaction of taxes.
d) Demonstrate the skills expected of the Chartered Tax Practitioner

THE SYLLABUS

The ascertainment and computation of income and income tax payable by individuals,
corporate entities, partnerships, trusts and other unincorporated businesses

The computation of reliefs and capital allowances

Taxation of employment income; Tax treatment of Retirement Savings and Life

Insurance Premiums

Application of the correct rates of import duties, value added tax, special tax, excise
duties, and other prevailing taxes on exports, imports and locally produced goods.
Determination of the correct classification of goods and true value of goods

Computation of Mineral Royalties

Taxation of Petroleum, Minerals and Mining entities
.
The application of the principles in respect of cessation of trade on liquidation or
reconstruction or amalgamation

Taxation of Insurance business; Short-term insurance and life insurance

Ascertainment of Capital Gain and Computation of Capital Gain Tax; Valuation and
Taxation of taxable gifts

Application of provisional and self-assessment rules and their relationship to business

financial decisions

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Application of Tax Accounting principles and Taxation rules for determining income
Cash basis accounting; Accrual basis accounting; Prepayments; Claim of right; Long-
term Contracts; Trading stock; Debt obligations; Jointly owned investments; Indirect
payments and benefits; Recouped expenditure.

The treatment of the following issues in taxation

Hedging
Distribution by corporate entities
Roll-over reliefs
Collateral benefits
Profit or dividend stripping

The general application of statutes and case law decisions to practical problems
.

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FINAL LEVEL 2 - PAPER 12

TAX PRACTICE ADMINISTRATION & ETHICS

OBJECTIVE

To ensure that students acquire in-depth knowledge of tax administration procedures and
develop a thorough knowledge and understanding of tax compliance issues and be conversant
with the implications of non-compliance.

THE SYLLABUS

The Structure and Functions of Revenue Agencies

The structure and functions of the Ghana Revenue Authority

The powers of the Commissioner General of the Ghana Revenue Board
Delegation of duties and powers of the Commissioner General
The definition of Commissioner General in administration of taxes
Functions of custom administration: revenue and non revenue functions; agency duties; duties
of customs officer; duties of excise officer; duties of preventive officer; reasons for
prohibitions and restrictions on imports and exports

The Tax Compliance Process

Assessment and filing of return procedures relating to Income Tax, Capital Gains Tax, Gift
Tax, other taxes and levies
The assessment procedures of Customs, Excise, Export, and Import Duties, and Special Taxes
and Value Added Tax
Goods-in-transit procedures
Preparation of Customs Entry Forms
The import entry and export entry making processes
Valuation for customs purposes
Import entry declaration and procedures for clearing goods
The conditions and procedure for duty drawback
The entry procedure for free zones goods
Custom warehousing, bonds and securities
The preparation of returns for communication service tax and payments
The due dates for filing returns and payment of Income tax, VAT, Duties, Special Taxes
Preparation of VAT Returns and payments
The documentation requirement of imported service
.

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Collection Procedures: Collection of Tax by attachment and garnishment; Tax as a debt to
Internal Revenue Service, Customs, Excise, and Preventive Service and Value Added Tax;
Duties of receivers. Recovery of tax from agents: Appointment of agents for the collection of
taxes.
The procedure for remissions, refunds and set-off of taxes

Objections and appeals procedure: the process of resolving disputes

The procedure for imposing interests and penalties
How to deal with tax offences
Offences and Penalties for non compliance of transfer pricing rules and regulations
Tax forms and notices: Procedure for serving notices and other documents; Documents
containing mistakes.
The process and conditions for obtaining and issuing Tax Clearance Certificate Tax
Identification Number (TIN)
Preparation of tax schedules and tax returns for compliance purposes
The meaning and interpretation of terms specifically used in the authoritative sources of
revenue law.

The Tax Consultancy Process

Managing the phases of the consulting process:
The relationship building phase of the process: entry and contracting stages; the information
phase; the action phase; the feedback and terminating procedure of the tax consultancy process.
The authoritative sources of Revenue law:
Statutory law, administrative interpretation, judicial interpretations, and tax treaties;
Secondary sources, tax periodicals, tax services and tax manuals:
Tax research: the elements of tax research; the process of conducting tax research

Professional, Legal Rules and Practice Guidelines

Legal rules: ownership of documents; retention of records and time limits; information requests
from revenue agencies; requests from other parties; data protection:

Professional standards and guidelines issued by the profession both in Ghana and international:
practice governance and management; client services; complaints; dispute resolution between
clients and practitioner; dispute resolution between practitioner and third parties; training and
continuous professional development:
The professional responsibilities of members in employment:

The ethical aspects of taxation practice: managing ethical behaviour in tax practice

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EXEMPTION POLICY
1. No exemption is available at the Final Examination Levels.

2. Exemptions are at the discretion of Council.

3. Holders of the Taxation Technician Certificate are exempted from

Paper 1 Public Sector Economics & Finance

2 Income Taxation
4 Indirect Taxation

4. Members of the following professional bodies may be exempted from the professional
level examinations.

Ghana Bar Association

Institute of Chartered Accountants (Ghana)
Chartered Association of Certified Accountants (ACCA) of UK
Institute of Chartered Management Accountants (ICMA) of UK
Chartered Institute of Public Finance & Accountancy (CIPFA) UK

5. Exemption for all other qualifications will be on subject to subject basis provided
evidence is adduced that the student attained the level of knowledge and the standard
required.

6. Exemption is not available for an incomplete qualification

7. Fee is charged per paper exempted

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TRANSITIONAL ARRANGEMENTS

1. Students who completed the old Level 1 examination are to start from the Professional
Level of the New Scheme.

2. Students who partly completed the old Level 1 will be automatically registered as a student
for and exempt from the Taxation Certificate Examination on subject to subject basis. Such
students will be de registered as students of the professional examination scheme

3. Students who partly completed the old Level 2 examinations will have their passes credited
at the new professional level on subject to subject basis

4. Students who completed the old Level 2 examination are to sit the following papers in the
Final Levels of the new syllabus to complete:

Paper 7 Tax Audit and Investigations

Paper 10 Strategic Tax Planning
Paper 11 Advanced Taxation Practice
Paper 12 Tax Administration

5. Students who have referred papers at the old Level 3 will have to write the referred papers
as follows:

Old Scheme New Scheme

Paper 13 Advanced Taxation Practice Paper 11 Advanced Taxation Practice
14 Tax Audit & Special Investigations 7 Tax Audit & Investigations
15 Tax Administration 12 Tax Practice Admin & Ethics
16 Strategic Tax Planning 10 Strategic Tax Planning

Students must sit and pass the referred paper before or during the February, 2013 examination
session. Students who fail to sit and pass their referred paper before or during the February,
2013 examination session are to start the examination scheme from the new Final Level 1.

6. The new examination scheme and syllabus take effect from August, 2011 and will be
examined for the first time at the February 2012 examinations.

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