More about the ADIT papers


To gain the full ADIT qualification you must pass the compulsory Module 1 and any two from the other module options.

You can choose to sit all the ADIT modules (or papers) together, or to sit them over two or three sittings. That decision, along with how you approach the ADIT qualification, can be crucial to your exam success. The modules you choose generally reflect the areas of taxation you currently work in, or have an interest in.

Tolley Exam Training provides study support for the following papers:

Compulsory moduleJurisdictional modulesThematic modules
1 Principles of International Taxation 2.09 UK Option 3.01 EU Direct Tax Option


3.02 EU VAT Option


3.03 Transfer Pricing Option


3.04 Energy Resources
Module 1 Principles of International Taxation

Module 1 is the only compulsory paper. It has a focus on the work of the OECD, in particular the OECD Model Treaty. In addition, the paper includes consideration of other treaties, such as the UN Treaty and the US Model Treaty, and various international agreements, for example in the area of information exchange.

Those who have worked in international tax, or had some exposure to cross border tax issues, are likely to have used treaties at work and a key part of the syllabus is analysing and interpreting the different articles in the OECD Model Treaty.

Other study areas include the basic principles of International tax law, such as the concepts of residence and source and how conflict in such concepts can give rise to double taxation, plus areas including international tax avoidance and transfer pricing.

Note, it is not a requirement to have already worked in international tax as the Tolley Exam Training study material starts from first principles and builds. However, students will need a general background in tax, either through practice or study.

This module is topical and so is the Tolley Exam Training study programme, keeping you up to date with relevant developments and cases.

Every student must demonstrate that they can apply the theoretical concepts to a practical situation and this is very much the ethos of ADIT, application. Our practical online courses and study materials guide students through case studies to develop the application skills required.

Jurisdictional modules and 2.09 UK option

The jurisdictional modules deal with the overseas and cross border aspects of those jurisdictions’ tax regimes.  These papers assume a high level of existing knowledge of the tax regime (effectively CTA level of knowledge for the 2.09 UK option) and then the focus of the exam is on the overseas and cross border aspects.

Tolley Exam Training offers study support for 2.09 UK Option. Most UK students, who have experience in UK tax would consider sitting this paper.

Basic knowledge of how the UK’s tax system works for income tax, corporate tax, national insurance, inheritance tax, VAT etc. is assumed.  The paper focusses on the advanced cross border issues (matters such as the hybrid mismatch rules, the CIR rules, the updated non domiciles rules etc.).  The syllabus is broad, as it covers both individual taxation and corporate taxation.

Thematic modules

Thematic modules are essentially non-jurisdictional and focus on an overall theme.

3.01 EU Direct Tax Option

This module examines the impact of European Union Law on all aspects of direct taxation for all Member States. The module includes the background to EU Law in the Treaties, and the role of the various EU institutions. There is a focus on the case law of the CJEU in direct tax matters, approached on a topic by topic basis.

3.02 EU VAT Option

This module examines EU Law on VAT which governs the VAT system in all Member States. The module includes the fundamental concepts of EU Law, the Principal VAT Directive and other EU VAT legislation. This module is aimed at the VAT practitioner.

3.03 Transfer Pricing Option

The Transfer Pricing Module focuses on global transfer pricing principles and issues. There is a focus on the OECD approach with the OECD Model Treaty and OECD Transfer Pricing Guidelines. Therefore, there is a cross over with the transfer pricing elements of Module 1 Principles of International Tax.

This is a practical module and often chosen by those working in transfer pricing. However, the Tolley Exam Training study material does not assume any basic knowledge, and instead explains the theory and provides case studies to aid practical understanding. Therefore, this module is a good foundation for those who want to learn about this area.

3.04 Energy Resources

Please note that the June 2022 ADIT Paper 3.04 exam will only examine the syllabus content in relation to Upstream Oil and Gas.

This module examines the taxation of upstream oil and gas operations in an international context. The module addresses fundamental tax issues within the oil and gas sector, including a number of country examples as specified in the syllabus, permanent establishments and transfer pricing methods, the taxation of intellectual property, mergers and acquisitions, financing and trading activities within the sector.

This module was traditionally chosen by those working in the industry but has more recently attracted a wider student base. The syllabus includes not only the actual oil and gas company subject to the ring fence regime, but also service and finance companies within a group and examines areas such as WHT issues, hybrids, CFCs and residency (also in Module 1), and transfer pricing (in Modules 1 and 3.03). There is also an opportunity to use the UK as an example in areas such as restructuring (overlapping with Module 2.09).

The Tolley Exam Training study material recognises students approach this module from various backgrounds so does not assume any basic knowledge and instead provides a good foundation for those who want to learn about this area.

Tolley Exam Training recommendations

Order of modules

The ADIT exam papers can be sat in any order. However, many students start with Module 1 Principles of International Taxation as it provides some foundation knowledge in international taxes generally, or a module in their specialist field.

Consider sitting modules with overlapping topic areas together

Where there is an overlap in syllabus you may want to consider sitting two exam papers at the same sitting to reduce any re-learning. For example, there is an overlap with transfer pricing in modules 1 and 3.03. Module 3.04 Oil and Gas also overlaps with modules 1, 3.03 and 2.09.

Recommended schedule

Although all three ADIT exam papers can be sat at the same sitting, we recommend you consider the amount of work involved and any prior engagements before committing. Often ADIT exam papers are sat one at a time.

The CIOT suggest as a rough guide, the study time needed is 140 hours for Module 1 Principles of International Taxation and 200 hours each for the option modules. Time needed will vary depending on your own background and circumstances.

The Tolley Exam Training Key to ADIT Exam Success

At Tolley Exam Training, we want you to pass with confidence. Our study options provide the three key ingredients to exam success:

  • Know your subject
  • Know your exam
  • Practice, practice, practice
Know your subject

Tolley Exam Training has been delivering ADIT training since 2006 and it is our experienced ADIT tutors who write the ADIT study materials and design the classroom courses. Our study manuals are syllabus specific with clear explanations, illustrations and examples to take you from first principles.

Know your exam

Passing the ADIT qualification is not just reading study materials and repeating facts. It is applying the knowledge and delivering a comprehensive, professional and reasoned argument. Our study materials and case studies are designed to help you build the skills needed to succeed.

Our study support includes practice and mock exams where you can submit your answer scripts for marking and feedback.

ADIT exam papers are online and so are the Tolley Exam Training practice and mock exams. We have built our own Timed On-screen Mock (TOM) system which replicates the experience of the CIOT’s Exam4 programme used in the final exam.

Practice, practice, practice

Applying knowledge to practice questions is absolutely essential. We have case studies and a series of question banks that get progressively harder as you work through the study programme building up to exam standard questions.

We are always prepared to discuss your options with you before you apply to sit the exam papers.