🚨 Key Changes to the ADIT Principles of International Taxation Module: What You Need to Know

What’s changed?
The Part A section of the exam – which features essay-style conceptual questions – has been trimmed from five questions down to three. Candidates are still required to answer two of them.
Part B (scenario-based questions) remains the same with two compulsory questions. So, the total number of questions has dropped from seven to five, while you’ll still need to attempt four questions overall (2 from Part A, 2 from Part B).

Why the change?
This adjustment aims to:

• Improve fairness by ensuring consistent difficulty across the paper.

• Encourage students to master core areas rather than focusing narrowly on a few preferred topics.

• Reduce the risk of “question dodging,” especially on foundational topics like double taxation conventions.

What this means for you:

• You’ll need a broader understanding of the syllabus.

• Focus on building a strong baseline knowledge rather than selective depth.

• No new sample paper will be issued, but existing past papers are still highly relevant.

What’s changed?
For the first time, the syllabus gives equal weight to both the OECD and UN Model Tax Conventions. Previously, there was a strong 80/20 focus on the OECD MTC – but going forward, the UN Model is no longer optional reading.

Why this matters:

• The UN has become more influential in international tax governance.

• Many ADIT candidates come from jurisdictions where the UN MTC is more relevant.

• The syllabus update reflects the diversity of the global tax profession.

How to prepare:

• You’re now encouraged to refer to either or both model conventions in your answers.

• If your response adds value by comparing the two models, you may earn extra credit – but only if it’s relevant and well-argued.

• Some questions may specify a model (e.g., Article 12B is unique to the UN MTC), while others will allow you to choose based on your expertise.

Reassurance from CIOT:
You won’t be penalised for focusing more on the OECD model. This transition will be gradual, and the exam will remain fair and flexible to accommodate different backgrounds.

What’s changed?
The syllabus now covers taxation challenges arising from:

• Artificial Intelligence

• Cryptocurrencies

• Digital business models

Why this matters:
These topics reflect the real-world evolution of global commerce, and understanding them is increasingly vital for any international tax professional.

How this affects the exam:

• These areas have been added or strengthened in the syllabus, but they won’t dominate the paper.

• You’re unlikely to see entire questions on AI or crypto.

• Your study time should be proportional to their modest syllabus weight.

While these updates mark a significant evolution in the Principles of International Taxation module, they’re not meant to make the exam harder. Instead, they aim to standardise expectations, reflect modern realities, and support candidates from all corners of the tax profession.

As Rory Clarke emphasised:

“This isn’t a radical shift — it’s about empowering students to represent the international tax field more fully. Use the syllabus as your roadmap, and don’t panic. You’ve got this.”