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Mastering the ADIT Exam:

2024 Guide for the Transfer Pricing Module


WHY READ THIS GUIDE

I wrote this guide for my students to enhance their chances of


passing the ADIT Transfer Pricing exam. The methodology outlined
here has led to 98% of students passing on their first try. Now, I am
making it freely available. It includes three crucial elements:

1. Skills you must master to pass the exam (page 4)


2. Preparation strategies (Page 6)
3. Additional hints and tips (Page 9)

Reading and implementing these suggestions will significantly


increase your chances of success – so be sure to read it through
to the end.

Visit my page for more free preparation resources:

www.startaxed.com

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MEET THE AUTHOR

Hi! This is me.

My name is Borys Ulanenko. Like


many of you, I understand the
daunting challenge of the ADIT
exam. With over a decade of
experience in transfer pricing,
including senior roles at KPMG
and Royal Dutch Shell, I thought I
was ready. But in 2018, when I
decided to earn my ADIT
certification, I faced unexpected
hurdles: a complex syllabus,
ambiguous requirements, and
expensive resources. It was
overwhelming, but it was also a
turning point.

After successfully obtaining my certification, I created a unique


ADIT preparation method that guarantees successful exam
passing (if you are ready to put in hard work, of course!).

This method isn't just theoretical; it's a tested pathway to passing


the ADIT transfer pricing exam on your first attempt. If you want
stress-free, structured, guided preparation and you are serious
about passing the exam - look no further!

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THREE SKILLS YOU MUST DEVELOP TO PASS THE
ADIT EXAM

Preparing for the ADIT exam requires a strategic approach,


blending practical expertise with theoretical knowledge.

You preparation strategy should equip you with these three


essential skills for success:

Efficient Navigation of OECD Guidelines

The OECD Guidelines are akin to a vital handbook for your ADIT
journey. You're allowed to bring an original copy to the exam, and
it's crucial to be familiar with it. Its comprehensive content is a rich
source for transfer pricing knowledge and contains insights
relevant to most ADIT questions. Given the time constraints of the
exam, proficiency in quickly finding and utilizing information from
the guidelines is key.

Practical Application of Transfer Pricing Concepts

The ADIT exam primarily tests your ability to handle practical case
scenarios, more so than theoretical queries. It's vital to be adept at
solving straightforward transfer pricing issues, choosing
appropriate methods, and understanding the pros and cons of
your selected approaches. Engage deeply with the examples in
this guide, practice with past exam questions, and study real-
world court cases to see these methods applied in action.

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Structured and Logical Writing

Clear and coherent writing is crucial, as even the most well-


thought-out ideas can be undermined by poor presentation. Be
prepared for various formats, whether it's a memorandum, a letter,
or an email. Stay focused on the question, avoiding irrelevant
details. Instead of extensively quoting the OECD Guidelines,
reference specific paragraphs when necessary. Organize your
thoughts into well-structured paragraphs and distinct sections,
each dedicated to a main idea. Remember, effective writing is a
key component of your success in the ADIT exam.

98% of my students pass the ADIT


exam on the first try
Visit www.startaxed.com to get more free preparation
resources

5
WHAT SHOULD YOUR PREP PLAN INCLUDE

Embarking on your ADIT exam journey requires a methodical and


well-thought-out strategy. Here's a comprehensive plan to build
the skills necessary for success:

1. Early and Consistent Study: Begin your preparation early,


ideally six months before the exam. Starting with short, daily
study sessions is more effective than cramming with longer
hours closer to the exam date. This early start will help you
gauge your pace and plan accordingly.

2. Leverage Online Learning Resources: If available, utilize the


StarTax Education ADIT course. These online lessons are
tailored for the ADIT exam and provide a solid foundation in
key transfer pricing concepts.

3. Thoroughly Engage with the textbook (if you have one):


Make sure to completely understand each chapter of the
textbook before progressing. Utilize the “check your
understanding” questions to reinforce your learning.
Repetition of material without referring back to the text is
crucial for building long-term memory.

4. Dive into Original Sources, Especially OECD Guidelines:


Reading the OECD Guidelines is essential. Start with this guide
or lectures to build a foundational understanding, then tackle
the Guidelines in manageable sections.

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5. Study Key Court Cases: Familiarize yourself with the
summaries of significant transfer pricing court decisions.
While memorizing every detail is not necessary,
understanding the application of principles in these cases is
vital.

6. Effective Note-Taking: Develop a system of note-taking that


works for you, whether it’s bullet points or mind maps.
However, be cautious with highlighting; it can create a false
sense of knowledge retention.

7. Practice with Past Papers: CIOT’s past exam papers are


invaluable. Use them to understand exam expectations and
to get a realistic sense of the exam environment. There are
two approaches: a slow, research-based method for building
knowledge, and a time-bound, exam-like practice for gaining
real exam experience.

8. Mock Exam Experience: If you have access to the StarTax


Education ADIT course, taking a mock exam is highly
beneficial. The feedback from trainers can help you identify
and improve your weak areas.

9. Review Before the Exam: Finally, revisit your notes and this
guide in the days leading up to the exam to refresh your
memory and reinforce your understanding.

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Following this structured approach will significantly enhance your
readiness for the ADIT exam, equipping you with the knowledge
and skills to excel.

8
IF YOU ARE EXPERIENCED PROFESSIONAL AND/OR
COMPLETED OTHER ADIT EXAMS

If you already possess practical experience in transfer pricing or


have previously passed the Principles of International Taxation
module, your approach to preparing for the ADIT exam might differ
from the standard recommendations. Your familiarity with key
concepts, such as the BEPS Project or the intricacies of permanent
establishments, may allow for a more streamlined study process.
However, even with this background, engaging with this guide is
advisable, as it provides a comprehensive summary and could
highlight areas in your knowledge that might need reinforcement.

Additional Advice and Strategies

1. Utilizing Existing Resources for International Tax Law

For those who have cleared the ADIT Principles of International


Taxation exam, you might already have "Materials on
International, TP and EU Tax Law 2020-21 Volume A: International
Tax Law" by Kees van Raad. This resource is a treasure trove of
international tax law essentials, including the OECD Guidelines. If
you're new to the ADIT exams and planning to take more in the
future, consider opting for van Raad’s book over a separate
copy of the OECD Guidelines. It encompasses a broader range
of material beneficial for other ADIT papers.

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2. Opting for the On-Screen Exam Format

The on-screen exam format is highly recommended due to its


flexibility. The text editor functionality allows for better
structuring of your answers. You can easily format, edit, and
reorganize your thoughts, sentences, and paragraphs, which
can be a significant advantage in presenting clear, well-
structured responses.

These tailored strategies and tips are designed to complement


your existing knowledge and experience, ensuring a more focused
and efficient preparation for your ADIT exam.

Visit my page for more free preparation resources:

www.startaxed.com

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