Chartered Institute of Taxation of Nigeria International Bureau for Fiscal Documentation Centre for Petroleum and Mineral Law Research invites applications for the 2015 AFRICAN FELLOWSHIP PROGRAMME in Energy Fiscal Valuation, Contract Administration and Tax Management (180 CREDIT UNITS TRANSFERABLE TO THE MASTERS IN BUSINESS ADMINISTRATION [MBA] DEGREE OF BAZE UNIVERSITY AND EXEMPTIBLE MODULES FOR MEMBERSHIP OF THE CHARTERED INSTITUTE OF TAXATION OF NIGERIA) Moderated by Baze University 1 2 Statement by the Chairman of the Joint Management Committee of the Africa Fellowship Programme in Energy Fiscal Valuation, Contract Administration and Tax Management Professor Keith Engel The 2014 Oil and Gas in Africa Report by Price Waterhouse Coopers (PwC) alerts that in the same year, a new oil and gas transaction came into place in Africa in every four days and that the value of these transactions in every seventeen days was USD$ 22.2 billion. The question that therefore arises is whether a fair representation of tax practitioners and other professionals such as lawyers of African descent were significantly involved as advisors in these transactions? It is this dismal, if not non – involvement of African professionals as fiscal regulatory or as contract management advisors in the major oil, gas, solid mineral mining or electricity transactions in the continent over the decades that has precipitated the establishment of the Africa Fellowship Programme (AFP) in Energy Fiscal Valuation, Contract Administration and Tax Management by the Centre for Petroleum and Mineral Law Research (CPMLR) in collaboration with the International Bureau for Fiscal Documentation (IBFD) and the Chartered Institute of Taxation of Nigeria (CITN) with a view to avail African tax, regulatory and contract management advisers with world class cutting edge negotiation, transactional and drafting skills. Upon successfully completing modules in the Africa Fellowship Programme in Africa Energy Fiscal Valuation, Contract Administration and Tax Management, the one hundred and eighty credits earned from the programme are fully transferable towards a postgraduate degree programme conducted by Baze University. Transferring students shall be expected to pay the prescribed exemption fee directly to Baze University. The transfer of such credits shall be subject to departmental requirements and attainment of departmental approval for exemption from the specific Masters Degree module(s). The Africa Fellowship Programme in Energy Fiscal Valuation, Contract Administration and Tax Management shall bring tax, legal, project finance and contract management professionals from Africa to Abuja for six months of post graduate-level study, leadership development and professional collaboration with counterparts in the oil, gas, solid minerals and electricity sectors. 3 The Joint Management Committee of this programme opted for the Africa Fellowship Programme, being an executive education training, rather than a masters degree programme, upon appreciation of the fact that an executive education approach is a more specialised pathway of study which provides its grandaunts with a tailor specific skills based training for their preferred sector and within half of the contact time for obtaining a masters degree. Additionally, the robust training which our Africa Fellowship Programme added to the option of transferring the 180 credit units earned on the programme to a Masters degree programme of Baze University provides is targeted at persons who are attaining the middle and senior management cadre in the taxation, financial, legal or contract management areas of the oil, gas, solid mineral or electricity sectors of the economy and therefore require in-depth training in order to effectively function as respected industry players in Africa’s fast growing oil, gas, solid mineral mining and electricity sectors. Having worked as a tax lawyer and as an academic for over three decades and a significant period of my career in Africa from the government regulatory as well as private sector advisory, I have come face – to-face with the challenges that young professionals in the continent encounter in an era in which businesses and business practices in the continent continue to re-invent themselves towards global competiveness. The foregoing has made it very imperative for young corporate and financial executives as well as project planning, tax and legal advisors in Africa to understand not only how businesses operate, but also how they make their policies. Similarly, business managers and corporate executives need to appreciate how tax policy specialists and tax administrators arrive at their tax assessments and the essence for a ‘win-win’. Our Africa Fellowship Programme therefore aims at building the conceptual underpinning for the upbraiding of business concepts and Africa’s tax policies from their silos and the bridging of expectations between emergent financial and corporate executives on the one part and regulatory and fiscal regulators as well as legal advisors on the other part, even at the foundational stage. This fusion of strategies towards a common agenda through cutting edge capacity building has become even more unavoidable with Africa’s emergence as the new frontier for global investments and the heralding of an era in which transactions have become technology savvy and increasingly borderless, even as countries through which these transactions materialise assert their sovereignty over corporate regimes and tax issues. As a tax policy adviser in Africa, I have seen the limitations in the current resource capacity for the negotiation and drafting of such transactions in Africa and how modernisation and transformation policies in one country without the same policy reforms in a neighbouring or transiting country or destination country does little good to the continent’s overall economic well – being. The networking by not only tax professionals, but also corporate, financial and legal professionals, from all over Africa for as long as four months while undergoing our Africa Fellowship Programme would therefore do great good to the continent’s economies. It is hoped that in a few years to come grandaunts of this programme shall become a resource pool of self - confident, globally competitive, highly knowledgeable and robustly skilled world 4 class experts of African descent in the tax, legal, financial, transactional and contract management of oil, gas, solid mineral and electricity. We would not only give you value in our training, but also the opportunity of a fulfilling career long networking with similar experts in all parts of Africa. I commend you for considering undertaking our combined Africa Fellowship Programme as a pathway to a Masters in Business Administration degree of Baze University. As you make your decision, please be guided by the fact that our programme is presently the only programme in the world that has combined academic modules with practical problem solving modules in tax, law, project finance and contract management for the extractive and energy sectors with a focus on Africa and which is delivered by a faculty of highly proven tax, project finance and legal international and national industry experts with decades of industry expertise in administration, transactions and teaching. It is therefore with profound pleasure that I welcome applicants to the course which is benchmarked and compares at par with similar programmes conducted by Ivy League universities and centres of excellence anywhere in the world. I look forward to welcoming you to the premises of Baze University which is the location for this course. Thank you. Professor Keith Engel, Chairman, Joint Management Committee, Africa Fellowship Programme in Energy Fiscal Valuation, Contract Administration and Tax Management & Deputy Chief Executive of the South African Institute of Tax Practitioners (SAIT) 5 Introductory Statement from the Director of Africa Energy Fiscal Valuation, Contract Administration and Tax Management Programme Dr. Perisuo Dema On behalf of the Management of the Africa Energy Fiscal Valuation, Contract Administration and Tax Management Programme, I am delighted to introduce the Africa Fellowship Programme (AFP) in Energy Valuation, Contract Administration and Tax Management to you. This programme is jointly conducted by the Centre for Petroleum and Mineral Law Research of Nigeria (“CPMLR”) in conjunction with the International Bureau for Fiscal Documentation based in the Netherlands (“IBFD”). The AFP is moderated by Baze University and the Chartered Institute of Taxation of Nigeria (“CITN”) who are respectively the academic and professional external examiners of the AFP. The Africa Fellowship Programme in Africa Energy Fiscal Valuation, Contract Administration and Tax Management consists of a curriculum of courses which are creditable (upon exemption by CITN) towards CITN membership examination modules as well as non-credit short courses and combines IBFD’s academic and research expertise. The programme is an energy and electricity management training which is law, project finance and tax focused. Ever since the discovery of petroleum in Africa in the mid-20th century, Africa has attracted and continues to attract huge global investments to her energy resources. In addition, the region has recently witnessed resurgence in her nations’ solid mineral and renewable energy sectors. An increasing number of international organizations such as the World Bank, the United Kingdom Department for International Development (DFID), the United States Agency of International development (USAID), the Canadian International Development Agency (CIDA), the Australian International Development Agency (AusAID) and the Chinese Government have rekindled interest in the sub-continent’s hitherto mining sector. 6 All these activities underscore the need to train African policy formulators, strategic planners, economists, project financiers, tax experts and lawyers with globally competitive skills with which to provide value chain services to Africa’s budding petroleum, solid mineral and renewable energy sector. As a result of the highly lucrative basket of commercial activities in countries within the African region, national policy makers and professionals in the energy sector face a huge challenge to robustly negotiate, draft and administer highly complex transactions in ways that will benefit citizens of the nations in the Africa region as well as investors. The Africa Fellowship Programme in Energy Fiscal Valuation, Contract Administration and Tax Management is structured to give students the requisite skills, knowledge and tools to become effective negotiators, drafters, project finance arrangers and contract managers. Although this programme will focus on hands – on training, students will have the benefit of being lectured by renowned global experts who will expose them to case studies and decades of practical industry experience gained within the region and internationally. The objective is that at the successful completion of this programme our grandaunts will join the list of highly sort after global experts in their area of specialisation. Our curriculum has accordingly been prepared with robust inputs by senior academics, industry leaders, recruiters and employers to ensure that our Africa energy law, project finance and tax Fellows are equipped to handle the challenges the energy and extractive sectors face in the 21st century. The Programme’s Management under the supervision of the Joint Management Committee is also committed to providing students with quality support facilities in the cause of their studies. Predicated on our training menu for the programme, we are confident that an Africa Energy Law, Project Finance and Tax grandaunt will provide endless opportunities for its recipients. We look forward to welcoming you to this programme. Dr. Perisuo Dema 7 About the Africa Fellowship Programme in Energy Fiscal Valuation, Contract Administration and Tax Management The Centre for Petroleum and Mineral Law Research (CPMLR) in conjunction with the Chartered Institute of Taxation of Nigeria (CITN) and the International Bureau for Fiscal Documentation of Amsterdam (IBFD) developed the Africa Fellowship Programme in Africa Energy Fiscal Valuation, Contract Administration and Tax Management. The programme which is moderated by Baze University will provide six months of post graduate level study and culminate in the transfer of the 180 credit units earned on the programme towards the Masters in Business Administration (MBA) degree of Baze University in any of the following four pathways: 8 Upstream Petroleum Valuation, Project Finance and Production Tax Management (a six months practical course on petroleum taxation, project finance and contract administration with emphasis on excel based modelling and valuation); Solid Mineral Valuation, Project Finance and Production Tax Management (a six months practical course on mineral taxation, project finance and contract administration with emphasis on excel based modelling and valuation); Electricity Econometrics, Project Finance and Tax Modelling (a six months practical course specialising in electricity econometrics with emphasis on excel based valuation, project finance and tax modelling); and Upstream Petroleum, Mining and Electricity Legal Risk Management (a six months course specialising in licensing legal / fiscal regimes, contract drafting, contract administration, project finance, risk management and arbitration for upstream petroleum, solid mineral production and renewable energy). Academic Qualification Status The Africa Fellowship Programme is equivalent to a Post Graduate Certificate course. Annual Course Work Duration (Two streams of six months each) a. September – February b. March - August [ How to apply and admission requirements Applicants are required to have an undergraduate degree in any subject as well have strong English and numeric skills. Once the completed application is received by our Administrative Officer, it shall take less than ten working days for a decision to be issued. The applicant will be notified whether or not a place on the programme has been offered. Completed applications can be submitted at any time and will be considered from June 1, 2015. The application cycle closes on August 15, 2015. We operate a “rolling admissions” process until all the available places are filled so applicants are recommended to apply early. Admission application forms can be obtained upon payment of Twenty = Five Thousand Naira (N25,000.00) to CPMLR’s current account (No.3232680015110) and sort code (No. 058083231) at any branch of Guaranty Trust Bank PLC of Nigeria from 1st May to 15th August 2015 and presentation of payment slip. Duly completed forms should be submitted by 15th August 2015 to: The Administrative Officer, Africa Energy Fiscal Valuation, Contract Administration and Tax Management Programme. 9 Structure and Schedule of Courses Delivery Face - to - Face Classroom Study: Delivery of modules of the programme shall be by classroom interaction, while tutorials and students’ academic discussions shall be facilitated through CPMLR’s web portal. The fee for the Africa Fellowship Programme: The current fee for programme is Four Thousand British Pounds (GBP £4,000) or One Million, Two Hundred Thousand Naira (N1, 200, 000.00). Criteria for Grant of AFP Certificate To obtain the AFP certificate, students are required to attend and participate in seventy – five (75%) of the lectures and to complete the assessments. Method of Evaluation Students shall be assessed through written examinations for each module. 10 Lecturers of the Africa Fellowship Programme in Energy Fiscal Valuation, Contract Administration and Tax Management: Contracts Administration Modules – The under listed persons are lecturers for the Contracts Administration Modules of our Africa Fellowship Programme. PROFESSOR IBIBIA WORIKA Professor Ibibia Worika is an Adjunct Professor with the African Energy Fiscal Valuation, Contract Administration and Tax Management Programme. He lectures our module “AFP - PGD 100: Legal Ownership and Energy Security of Natural Resources Production in the Africa”. He is a tenured Professor of Law at the University of Professor of Law at the University of Port Harcourt. Professor Worika recently worked as a Legal Adviser responsible for mineral resources at the Commonwealth Secretariat in London. Before his appointment at the Commonwealth, he was the Senior Legal Counsel of the Organization of Petroleum Exporting Countries (OPEC). Before that, he was a Senior Law Lecturer with the Faculty of Law of the University of Science and Technology in Port Harcourt, Nigeria as well as a Senior Associate with Anga & Emuwa, a firm of Legal Practitioners and Notaries, member of Meritas Attorneys World Wide. Professor Worika was a Commonwealth Academic Staff Scholar at the Centre for Energy, Petroleum & Mineral Law and Policy, University of Dundee, where he obtained his Ph.D. in International Environmental and Comparative Petroleum Law and Policy in 1999. He was also a post-doctoral research scholar at the Centre between 1999 and 2000. During this period and thereafter, he had either alone or in combination with others consulted for the European Union, United Nations Economic Commission for Europe (UNECE), United Nations University in Tokyo, Japan, the United Nations Development Programme (UNDP), a number of international non-governmental Organizations (NGOs), including the International Union for Conservation of Nature and Natural Resources (IUCN) in Bonn and the MacArthur Foundation in the United States. Dr. Worika has published widely in international legal journals including a book, Environmental Law & Policy of Petroleum Development in Africa, as well as several articles. 11 He is also a member of several international professional associations including the American Society of International Law (ASIL), International Bar Association (IBA) and the Climate & Energy Expert Group of the Commission on Environmental Law (IUCN). Professor Keith Engel The Deputy Chief Executive of the South African Institute of Tax Practitioners (SAIT), Professor Keith Engel, is a South African and the Chairman of the International Advisory Board of CPMLR. He was until recently the Director in charge of Tax Policy for Africa at Ernst &Young (now officially known as “EY”). Professor Engel is a South African citizen. Prior to joining EY, Professor Engel worked within the South African National Treasury in the development of tax legislation and eventually led the legislative tax process as Chief Director for many years. Professor Engel had earlier lectured at Washington & Lee University on the full gamut of United States tax issues and did visiting lectures at Boston University Law School, the Georgetown Law Center and University of Texas Law School. He also performed tax work at the Internal Revenue Service (National Office) of the United States Government and for two United States federal judges. Professor Engel obtained his law degree and his masters in taxation at the Georgetown Law Center. He will deliver aspects of the extractive sector tax policy module of our Africa Fellowship Programme . Dionisio Manuel Da Fonseca Dionisio Manuel Da Fonseca is an Angolan and the Special Adviser for Legal Affairs to the Vice President of Angola. Mr. Fonseca obtained a Bachelor of Laws degree from Augustino Neto University in 12 Angola, before earning a Master of Laws [LLM] degree in Oil and Gas Law from the University of Aberdeen in Scotland. Mr. Fonseca has worked in senior level legal positions in the Department for Operational Business and Concessions of Sonangol Exploration and Production, the Angolan national oil and gas company. He also worked as an Assistant Professor of Oil and Gas Law at his alma mater, the Augustino Neto University in Luanda, during which period he published several scholarly articles in peer reviewed journals. He had earlier worked as a Legal Counsel in the Luanda law practice of Carlos Feijó & Raul Araujo, Advogados Associados. He will deliver the comparative licensing module of our Africa Fellowship Programme. Dr. Thomas Kojo Stephens Dr. Thomas Kojo Stephens is a Ghanaian lawyer and petroleum policy analyst. He contributed to the conceptualization of the legal framework for the development of the petroleum sector of Ghana through his work as one of the senior counsels in the Accra based law firm of Akufo – Addo, Prempeh &Co. Dr. Stephens obtained a Bachelor of Arts degree in Political Science and Philosophy with a Summa Cum Laude from Emory University in the United States before graduating with a Bachelor of Laws degree from University of Ghana, before earning a Master of Laws [LLM] degree in Transactional Law from Cornell University in the United States. Dr. Stephens also has a PhD in Petroleum Law and Policy from the University of Aberdeen in Scotland which he successfully undertook as a British Commonwealth Scholar. He will deliver the petroleum licensing modules of the programme. Mr. Ahmed Yabo Ahmed Yabo is the Legal Adviser of the Nigeria-Sao Tome and Principe Joint Development Authority where he has coordinated the negotiation and drafting of all the current 13 petroleum exploration and production regulations, policies and guidelines for the joint development zone. Upon his attainment of an LLB in Nigeria, he attended the Nigerian Law School from where he was admitted to the Nigerian Bar. He subsequently graduated with an LLM in Energy Law and Policy in 2004 and an MSc with specialisation in Energy Finance in 2008, both from the University of Dundee. Additionally, Mr.Yabo has attended Executive Education programmes at world-class institutions such as Harvard Law School and Harvard Kennedy School of Government where he studied negotiation and international tax policy &administration, respectively; INSEAD, France; CWC School for Energy, UK; Rocky Mountains Mineral Law Foundation, USA and PetroSkills. Mr. Yabo will deliver some of the law modules of our programme. Dr. Perisuo Dema . Dr. Perisuo Dema is a Nigerian and the founding Director of CPMLR. He is concurrently a Senior Lecturer in the Law Faculty of Baze University, where he lectures all the modules on oil and gas law. Dr. Dema is also the Legal Adviser to the Nigerian House of Representatives Ad- Hoc Committee on the Petroleum Industry Bill, a position which he holds by virtue of his work as the Honorary Adviser on Petroleum and Taxation to the Deputy Speaker of the Nigerian House of Representatives. Dr. Dema’s work at the Nigerian National Assembly is supported through a grant from the Facility for Oil Sector Transparency and Reform (FOSTER), a project of the United Kingdom Department for International Development (DFID). He is concurrently working as the Consultant to DFID/FOSTER on the Nigerian Solid Mineral Mining Revenue. Dr. Dema had upon a similar consultancy engagement by the World Bank head office in Washington earlier advised the Government of Tanzania on legal and fiscal matters pertaining to her mining regime. Dr. Dema recently worked for the World Bank as its Fiscal Policy Consultant for its Nigerian Mining Sector Reform Project. Prior to the World Bank assignment, Dr. Dema earlier worked as the Assistant Director responsible for Oil, Gas and Mining in the Tax Policy Department of the Federal Inland Revenue Service (FIRS) of Nigeria. It was from the FIRS that he was head hunted to work as an Associate Director at the global interdisciplinary consultancy firm, Ernst &Young (EY). He resigned from EY to enable him give full attention to the seamless take- off of CPMLR and a full-time career in academics. Dr. Dema commenced his public service career at Nigeria’s Department of Petroleum Resources (DPR) where he worked as an in-house legal counsel from where he was seconded to the then Minister of Energy 14 as the Legal Assistant on Legislative Matters to the Minister. He left DPR to undertake an LLM degree training at the University of Aberdeen where he graduated magna cum laude in Oil and Gas Law. He followed up with a PhD programme in Reserve Based Finance Law also from the University of Aberdeen. He will deliver some of the legal modules of our Africa Fellowship Programme. DR. KAYODE ONIEMOLA Dr. Kayode Peter Oniemola is a Law Lecturer with the African Energy Fiscal Valuation, Contract Administration and Tax Management Programme. As a consequence of several of his publications in some of the globally most renowned peer review journals, Dr.Oniemola has become a well published specialist on the legal aspects of renewable energy as it pertains to Africa. Dr. Oniemola earned a Second Class Upper degree in Law from the University of Ilorin and was a Mac Arthur Foundation Scholar at the University of Ibadan from where he graduated with a Masters of Laws (LLM) degree before obtaining a PhD in Renewable Energy Law from the University of Aberdeen. Dr. Oniemola has practiced law in Nigeria and was appointed by the Federal Government of Nigeria as a Legal Consultant to help the then Oil and Gas Industry Committee (OGIC) to review the Petroleum Industry Bill (PIB). As a law lecturer with the African Energy Fiscal Valuation, Contract Administration and Tax Management Programme, Dr. Oniemola shall deliver the renewable energy components of the programme, particularly the legal aspects of the renewable energy modules. Tax Modules – The Coordinator of the Tax Modules of the Africa Fellowship Programme is Mr. Mark Dike. 15 Mark Dike Mr. Mark Dike is a Nigerian and the current President of the Chartered Institute of Taxation of Nigeria (CITN). He recently retired from the Federal Inland Revenue Service (FIRS) after a long and meritorious service spanning over three decades. While at FIRS he held various positions such as Director of Tax Policy and Tax Controller, Oil and Gas. Mr. Dike earned a Bachelor’s degree in Economics from Obafemi Awolowo University, Ile-Ife. He is an alumnus of the Tax Policy Programme of the Harvard Business School as well as a Fellow of the Chartered Institute of Taxation of Nigeria where he had been the Chairman of the Oil, Gas and Solid Minerals Faculty. Mr. Dike is a respected thought leader on taxation in Nigeria and possesses profound hands – on expertise in oil and gas taxation and tax audit shall be of tremendous benefit to students that would undertake the modules on tax policy which he shall deliver. The under listed persons are lecturers for the international tax and transfer pricing component of our Africa Fellowship Programme. They are coordinated by Belema Obuoforibo. Belema Obuoforibo Belema Obuoforibo is a Nigerian and the Director of the Knowledge Centre of the International Bureau of Fiscal Documentation (IBFD) as well as the IBFD in-house tax specialist for the United Kingdom. Before joining IBFD, she worked for many years in London as a UK Chartered Tax Adviser, specializing in the taxation of high net worth individuals and owner-managed businesses. Before becoming Director of the Knowledge Centre, she held various positions at IBFD, serving among others as Manager of the European Knowledge Group, and also as Principal Research Associate in the selfsame group. Obuoforibo is a member of the Technical Committee of the UK Chartered Institute of Taxation, specifically the International Taxes Sub-Committee as well as the Owner Managed Businesses 16 Sub-Committee. Obuoforibo is widely published in the field of cross-border taxation. Her experience as a lecturer in this area has taken her across Europe, Africa, Asia and the Caribbean. Obuoforibo has been an Editor at LexisNexis. She was educated with an LLB (Hons) from Makerere University in Uganda and at the College of Law of England and Wales .In addition to being a United Kingdom qualified Chartered Tax Adviser (CTA), she is also a Fellow of the United Kingdom Association of Tax Technicians (ATT). Obuoforibo is a tutor of the segment on Cross – Border Upstream Petroleum Taxation of the Africa Fellowship Programme. Their profiles are as follows: Kennedy Munyandi Kennedy is the Manager of the Africa, Middle East and Latin America Knowledge Group at IBFD. He has about 20 years of experience in tax administration, policy, research and publication, and government consultancy. His areas of interest include international tax law, investment tax incentives, and natural resources taxation. Kennedy has worked as a Senior Tax Inspector at the Zambia Revenue Authority and, on secondment, as a Tax Advisor at the Organisation for Economic Co-operation and Development (OECD). Kennedy holds an undergraduate degree in mathematics from the University of Zambia (1992), a postgraduate degree in international tax law from Leiden University (2005) and a certificate in comparative tax policy and administration from Harvard University (2011). Kennedy is one of the instructors for the principles of international taxation, and oil, gas and mining taxation modules. Ridha Hamzaoui Ridha is the Regional Manager for Africa and Middle East regions under the IBFD Africa, Middle East and Latin America Knowledge Group. He is an expert on tax treaties for the United Nations Development Programme in the Middle East region. He has a specialized master’s degree in tax law from the Tunisian University, an LLM in International Tax Law from the International Tax Center, Leiden University and a certificate in comparative tax policy and administration from Harvard University. He also graduated from the National School of Treasury in France where he successfully completed the postgraduate programme for Treasury inspectors. He has lectured for tax officials in 17 Uganda, Algeria, Egypt, Jordan, UAE and Syria. Mr Hamzaoui is also a regular speaker in the Africa/Middle East region on international tax issues and an instructor for the IBFD open and in-house courses. The topics covered include taxation of passive income, international tax aspects of employment income, attribution of profits to PEs and the interaction of anti-avoidance rules with tax treaties. Before joining IBFD, he worked as a senior tax advisor within the Tax Legislation General Directorate of the Tunisian Ministry of Finance for four years and lectured for tax officials at the Ministry of Finance training institute. He also lectured at the Vrije Universiteit of Amsterdam and the Tunisian University. Ridha is one of the instructors for the principles of international taxation, transfer pricing, and oil, gas and mining taxation modules. Monia Naoum Monia is a Research Associate in the Africa, Middle East and Latin America Knowledge Group at IBFD Amsterdam. She is a country specialist of a set of French and Arabic speaking countries in the Middle East and Africa. In addition to publications about the tax systems of the countries in her portfolio, she regularly participates in cross-border taxation research projects and client requests. Before joining IBFD in 2011, Ms. Naoum worked as a tax official at the Moroccan tax authorities, where she was dealing with the corporate taxation aspect in the operational services. Prior to that, she enrolled in an 18-month executive training programme in taxation at the Moroccan Tax Administration Training Centre. Ms. Naoum graduated from the Institut National de Statistique et d’Economie Appliquée in Morocco with a Masters of Engineering degree in Operations Research and Strategic Management. In 2014, Ms. Naoum successfully concluded the advanced LLM program in International Taxation at the University of Leiden, the Netherlands. Monia is one of the instructors for the principles of international taxation, transfer pricing, and oil, gas and mining taxation modules. 18 Carlos Gutiérrez Carlos is a Principal Research Associate at the IBFD Knowledge Centre. Mr Gutiérrez obtained his law degree at the University of Chile and a master’s degree (LLM) at Queen Mary College, University of London. Prior to joining IBFD, he was a legal adviser with the International Legislation Department of the tax authority of Chile (SII), responsible for tax treaty negotiation and interpretation, and for drafting direct tax legislation. He has represented IBFD at various seminars and conferences, and he has regularly taught for IBFD International Tax Training in open courses as well as tailored in-house courses for governments and advisory firms in different countries. He also taught International Tax Law in the international LLM programme of the Vrije Universiteit Amsterdam. Carlos is one of the instructors for the principles of international taxation, transfer pricing, and oil, gas and mining taxation modules. Lydia Ogazón Lydia is a Senior Research Associate at IBFD's Africa, Middle East and Latin America Knowledge Group. At IBFD, she is the country specialist for Mexico and other Latin American countries. She is responsible for various IBFD publications involving those countries and regularly participates in cross-border taxation research projects and client requests. Before joining IBFD, Ms. Ogazón worked for over 12 years for the International Tax Treaties Unit of the Ministry of Finance in Mexico and the Group Taxation Unit within the same Ministry. She was a member of the Mexican delegation for the negotiation of double tax treaties and tax information exchange agreements and the Mexican Substitute Delegate to the OECD Working Party 6 on the Taxation of Multinational Enterprises and the OECD Forum on Harmful Tax Practices. Prior to joining the Ministry of Finance, Ms. Ogazón worked for E&Y Mexico as a tax adviser and auditor. Ms. Ogazón is a member of the Mexican College of Public Accountants. She is a certified public accountant with a Public Accounting bachelor’s degree from the Instituto Politécnico 19 Nacional of Mexico and a Diploma in International Taxation from the Instituto Tecnológico Autónomo of Mexico – Duke University. Lydia is one of the instructors for the principles of international taxation and transfer pricing modules. Monica Montes Monica is a Research Associate at IBFD Knowledge Center Africa, Middle East and Latin America Knowledge Group. She joined IBFD in 2013, after having successfully completed her LLM in International and European Tax Law at Maastricht University (the Netherlands). Previously, she worked for the Telefonica Group in Peru, supporting its tax direction regarding the tax for non-residents and the application of double tax treaties for compliance and tax planning. Before that, she worked in the tax law practice of several law firms dealing with local and international clients and as a professor’s assistant for the Tax Code course at the Postgraduate Programme of Taxation at the University of Lima. Ms. Montes is a member of the Bar of lawyers in Lima. She graduated in Law at the Pontifica Universidad Católica del Peru and complemented her tax law career with several accounting courses at the Business & Management faculty of the same university. Monica is one of the instructors for the principles of international taxation and transfer pricing modules. Anapaula Trindade Marinho Anapaula is a researcher for the IBFD Africa, Middle East and Latin America Knowledge Group. She has been working for IBFD since 2011, after 8 years of teaching at the Sorbonne University (Paris 1). Her key areas of specialization are Individual and Corporate Taxation, oil and minerals taxation, Comparative and International Tax Law. At the IBFD, Ms. Trindade is responsible for a portfolio of 10 African countries. She is also part of the researchers working on client research, governmental consultancy and instructor of tax officials on international taxation and transfer pricing. 20 Ms. Trindade is also a lecturer on tax reform in Africa and Latin America and French tax law at the University of Economics of Paris Dauphine (Paris 9 – France). She has a DEA (Diplome d’Etudes Approfondies) /Master 2 on Tax Law from the University Panthéon-Sorbonne (Paris 1) that she concluded successfully (Major of the promotion). Ms. Trindade is currently also working on the finalization of her post doctoral degree on International Tax Law at the University Panthéon-Sorbonne (Paris 1) and has published several articles on domestic and international tax law in prestigious reviews and books. Ms. Trindade is fluent in French, English, Portuguese, Spanish and Italian. Emily Muyaa Ms. Muyaa is a Research Associate in the Africa, Middle East and Latin America Knowledge Group at IBFD Amsterdam. She is a country specialist of a set of English speaking countries in Africa. Emily regularly participates in cross-border taxation research projects and client requests in addition to being responsible for various publications and other tax content relating to the said African countries. Before joining IBFD in 2014, Ms. Muyaa worked in the Transfer Pricing Division of the Large Taxpayers Office at the Kenya Revenue Authority. She holds a certificate in tax administration from the Kenya Revenue Authority Training Institute for various tax heads; VAT, Income Tax, Customs and transfer pricing. Ms. Muyaa holds an undergraduate degree in law from the University of Nairobi, a postgraduate diploma in law from the Kenya School of Law and an LLM in international taxation from the International Tax Center of the Leiden University in the Netherlands. Ms. Muyaa also holds an advanced diploma in accounting and business from the Association of Chartered Certified Accountants (ACCA). She is an advocate of the High Court of Kenya and a member of the Law Society of Kenya. Ms. Muyaa is one of the instructors for the principles of international taxation, transfer pricing and oil, gas and mining taxation modules. 21 Introducing the Centre for Petroleum and Mineral Law Research Centre for Petroleum and Mineral Law Research at Auta – Balefi, Km 26, Abuja – Keffi Expressway, Nasarawa State, Nigeria International Advisory Board In compliance with its Articles of Association which prescribes a seven (7) members’ International Advisory Board, CPMLR have accordingly appointed a multi-disciplinary nine members’ International Advisory Board who all have extensive international development experience and are highly experienced administrators, strategic planners, international oil, gas, solid mineral, renewable energy, transactional and tax advisory lawyers and experts. Our International Advisory Board provides strategic guidance and governance oversight. The members of CPMLR’s International Advisory Board are: Professor Keith Engel - South Africa Mr. Mark Dike - Nigeria Mr. Dionisio Manuel Da Fonseca - Angola Dr. Thomas Kojo Stephens - Ghana Mr. Ahmed Yabo - Nigeria Ms .Belema Obuoforibo - Nigeria Dr. Perisuo Dema - Nigeria 22 Honorary Fellows Election as an Honorary Fellow of CMPLR is the highest honour the Centre can confer. CPMLR recognizes distinguished jurists and petroleum industry experts whose work and / or scholarship has shaped the broad discipline of the investment, legal and fiscal aspects of upstream petroleum, solid mineral and electricity and influenced the work of others. To honour the contributions of such extraordinary individuals, CMPLR has created the designation of Honorary Fellows in order to recognise those who have made outstanding contributions to development of the standards the CPMLR subscribes to. The key facilities in the start – off complex of the CPMLR include: Conference Hall (40 feet [ft] x 16 ft) Seminar Room (21ft x 21ft) Lecture Room ( 26.7 ft x 11.4 ft) Reading / E – Library and Web Portal - CPMLR has a reading library spanning a space of 18.10ft x 15.2 ft. The reading library contains printed copies of leading and authoritative books, journals and other publications on the modules covered in the various courses of the Centre. The library also provides online e-library and web portal services. Canteen ( 20.8 ft x 9.5 ft) Five [5] offices for academic and non-academic staff Government and Regulatory Authorities’ Approval as Training Institute The CPMLR is approved by the Federal Ministry of Education of Nigeria vide reference number: FME/TED/A&E/ANPD/XLII/T/164 to conduct courses in oil, gas and solid minerals management, law, taxation and finance and to accordingly award an African Fellowship Programme (AFP) Qualifying Certificate. Provision of training in International Taxation and Cross – Border Taxation CPMLR is collaborating with the Amsterdam based International Bureau of Fiscal Documentation (IBFD) to conduct specialized training on all aspects of international 23 taxation for all West Africa based tax practitioners and executives whose duties are impacted by international taxation. IBFD shall with the logistic support of CPMLR thus conduct training courses tailor made for ECOWAS countries from the facilities as provided by CPMLR. Executive Training As part of its executive training, CPMLR shall also conduct short courses spanning one day to one week on any subject matter within the Centre’s focal areas – trans-national economic cooperation, trans – national dispute resolution, legal, policy, tax, project finance, investment and supply chain management issues relating to oil, gas, solid mineral and renewable energy. 24 EVENTS Previous Events In September 2010, the Centre for Petroleum and Mineral Law Research conducted the first ever Petroleum Contracts Administration and Upstream Tax Workshop for Judicial Officers and Lawyers in Nigeria FACULTY Ifueko Omoigui – Okauru Dr. Bayo Adaralegbe Tunde Aribido Gbenga Biobaku Kofo Dosekun Professor Yinka Omorogbe Bede Nwete Dr.Mark Igiehon Uche Nwokedi, SAN Theo Emuwa 25 PARTICIPANTS Special Representative of Federal Attorney General and Minister for Justice Honourable Judge from the High Court of the Federal Capital Territory Lawyers from the Nigerian National Petroleum Corporation (NNPC) Lawyers and investment advisers from Shell Petroleum Lawyer from First Bank PLC Honourable Judges from the Federal High Court Honourable Judge from the High Court of Bayelsa State Lawyer from Century Energy Limited Officials from Exxon Mobil Lawyers from Diamond Bank PLC 26 Contact Us Email: [email protected] Tel: (234) 809 811 3714 27 AFRICA FELLOWSHIP PROGRAMME (AFP) IN ENERGY FISCAL VALUATION, CONTRACT ADMINISTRATION AND TAX MANAGEMENT lectures holding @ Course Outline and Codes of Modules 28 DESCRIPTION OF COURSES AND CONTACT HOURS The total number of contact hours for the programme is one hundred and eighty (180) hours. It is important to state that each of the modules of our Africa Fellowship Programme can be taken as stand-alone short courses by persons who are not interested in graduating with our Africa Fellowship Programme and which brief period of training would count as Continuing Professional Development (CPD) hours of the Chartered Institute of Taxation and the Nigerian Bar Association, depending on whether the module is approved as a Continuing Professional Education (CPE) by either of the two professional bodies. The details of the modules and the time allotment(s) are as follows: Course Codes, Aim, Outline and the contact hours of the various courses AFP 100: Legal Ownership and Energy Security of Natural Resources Production in the Africa a. AIM The aim of this module is to introduce students to legal, legacy and contemporary issues pertaining to the ownership of natural resources in Africa and how these legacy issues have affected the development of the natural resources in the continent as well as the continent’s long term strategic interests vis-à-vis the tripartite (English, Portuguese and French) trajectory of the continent. An understanding of these fundamental issues would give the student a good foothold on the Africa Fellowship Programme and its prospects as Africa pursues her energy security. b. CONTACT HOURS (NINE HOURS) This module is divided into three parts of three hours each on two different days: the political economy aspect and the energy security aspect. 29 AFP 101: Contemporary Tax Policy and Regulatory Matters a. AIM This module shall acquaint students with the evolution and objective of the tax system in Nigeria, Features of a Good Tax System, general system of tax administration, problems and prospects, tax laws, administration of income tax, value added tax, capital gains tax, petroleum profit tax, the structure and functions of tax authorities at federal and state levels, joint tax board, the theory of economic stabilization and impact of fiscal policy; while the second three hours of the module shall acquaint students with the interrelationship between stakeholders in the development of a good tax system, The role of stakeholders in developing a good Tax culture in Nigeria, Funding of the Tax and Revenue Authorities, Tax Refund Mechanism. Periodic Review of existing Tax laws, Coordination of Tax Authorities by the Joint Tax Board, Tax Appeal Process and using tax system as a tool in creating competitive advantage as well as the issue of tax incentives. b. CONTACT HOURS (TWELVE HOURS) This module is divided into two parts of six hours each on two different days. AFP 102: Double Tax Agreements, Tax Information Agreements and Bilateral Investment Treaties and Regional Economic Cooperation Agreements and their impact on Source Rules versus the Resident Rules in negotiating Oil, Gas, Solid Mineral and Electricity Production, Turn- key Service Contracts and Offshore Rig Hire Contracts in Africa a. AIM The aim of this module is to provide the student with a good understanding of international tax treaties, tax information agreements and bilateral investment treaties as well as their impact on oil, gas and solid minerals production as well as electricity generation and turnkey projects as well as the legal and fiscal regimes for offshore rig hire in African countries. 30 The course would involve training on tax treatment of turn-key contracts by non-resident international staff as well as the taxability of the online role through the internet by a nonresident expert in a particular foreign country. Students would be exposed to the taxing regime for extractive industry production operations under the Source Rules and also under Resident Rules. b. CONTACT HOURS (TWELVE HOURS) The total number of contact hours is twelve hours divided into three different days. AFP 103: Concessions, Licensing and other Production Contractual Issues in the Africa’s Extractive Field Development a. AIM The aim of this module is to strengthen the students’ capacity to effectively negotiate and draft robust terms in oil and gas upstream operatorship and lease agreements under concessionary, licensing and/or production sharing agreements. The essence of the module is also to ensure that upon completion of study, students would be able to effectively negotiate and draft clauses for Joint Operating Agreements, Sole Risk Agreements and Technical Service Agreements for petroleum concessions and other extractive industry licencing and production contracts to the benefit of their clients. Students shall also acquire the negotiation and drafting skills for the bidding and auctioning of oil, gas and solid minerals acreages under licencing and concessionary legal frameworks, while taking into cognisance due diligence and fiscal issues when negotiating such transactions. Students shall also be exposed to the issues of Ministerial Consent and Back – In Rights under the Petroleum Act. b. CONTACT HOURS (NINE HOURS) The contact time for this module is nine hours divided into two days of three hours each. 31 AFP 104: Unitisation, Cross Unitisation, Cross Border and Joint Development Zone Transactions for Petroleum, Solid Mineral and Electricity Production in Africa: Legal and Tax Issues a. AIM The aim of this module is to acquaint students with legal as well as tax royalty issues pertaining to petroleum production in cross border, unitised, cross unitised as well as joint development zones which have been established as a result of straddling oil and gas fields. The module shall also treat the legal and tax treatment of solid minerals production and electricity generation from straddling hydro-power generation areas. b. CONTACT HOURS (NINE HOURS) This module shall be delivered in three days i.e. nine hours. AFP 105: Legal and Tax Issues on Decommissioning, Restoration and Abandonment of Petroleum, Solid Mineral and Electric Generation Facilities for in Africa, including provisions for Tax Deductibility a. AIM This module shall expose students to the legal issues pertaining to decommissioning, restoration and abandonment of offshore petroleum and electricity generation facilities as well as the legacy issues in cases where the licensing and / or operatorship of an acreage has been transferred without any expressed commitment for decommissioning, restoration or abandonment. It shall treat the issues of obtaining the approval of the respective Minister(s) and government departments concerned with decommissioning, restoration and abandonment. 32 It shall also treat the issues of the setting up of a ring fenced fund in an escrow for the decommissioning, restoration and abandonment process as well as the desirability for a suiting fund as well as the ancillary tax treatment and cost issues. Students shall also be exposed to processes for decommissioning, restoration and abandonment in matured provinces such as the United Kingdom Continental Shelf. b. CONTACT HOURS (TWELVE HOURS) This module shall be divided into two parts (the first part on decommissioning, restoration and abandonment of petroleum production facilities shall be delivered on the first two days i.e. first six hours); while the second part (on decommissioning, restoration and abandonment of electric generation facilities shall be delivered in the second six hours on the third and fourth days). AFP 106: Decommissioning, Restoration and Abandonment of Petroleum and Solid Mineral Facilities for Tax Deductibility: Legal Framework and Fiscal Modeling a. AIM This module shall educate students on the process, economic, costs, tax and legal issues pertaining to the decommissioning, restoration and abandonment of solid minerals in Africa as well as the ancillary environmental issues. b. CONTACT HOURS (SIX HOURS) This module shall be delivered in six hours, i.e. two days. AFP 107: Valuation of Petroleum Reserves in Africa a. AIM This module shall introduce the students to the methodologies for econometrics and forecasting of asset valuation of reserves of petroleum and solid minerals such as fair market value, probability and risk as well as risk adjustment in valuing petroleum assets, consideration of the portfolio approach to assets management, portfolio 33 optimisation techniques, Monte Carlo simulation techniques, investment decision analysis and simulation techniques. The essence of the module is to ensure that students acquire the techniques to determine the potential, probable and proven reserves of petroleum and solid minerals as well as determining the value-to-loan, Expected Present Value (EPV) and the Net Present Value (NPV) of reserves in a petroleum or solid mineral acreage with a view to ascertaining its volumetric production payments prospects while considering the underlying legal issues. b. CONTACT HOURS (TWELVE HOURS) Since this module is divided into two sections, the first section being on the principles and techniques for determining the reserve base of an oil or solid mineral well, it is earmarked for two full days i.e. six hours; while the second part, which deals with volumetric production payments, is for the third and fourth days i.e. another six hours. AFP 108: Transfer Pricing of Petroleum, Solid Mineral and Electricity Production: Impact on Supply of Technical Expertise and Services as well as Tax Base Erosion in Africa a. AIM This module shall introduce students to the issues of inter-related, inter-group, subsidiary and affiliate companies and the Arms-Length Principle generally and as it applies to oil, gas, mining and electricity companies with worldwide operations and their international staff who are frequently called upon to role in diverse regions. This module shall also review the OECD Rules and the UN Rules as it affects transfer pricing as well as the legal and tax issues that can militate against the operations of robust transfer pricing rules that can effectively drive petroleum 34 production by multinational petroleum producers and operators shall also be considered by the students. b. CONTACT HOURS (TWELVE HOURS) This module is divided into two sections. AFP 109: Tax Treatment of Petroleum Licence Areas during exploration, prospecting, development and production a. AIM This module shall introduce students to the tax treatment of petroleum licence areas from their exploration, prospecting, development and production stages. The module shall specifically introduce the students to the procedure and processes for the taxability of upstream petroleum joint ventures and production sharing contracts as well as the issue of ring fencing of petroleum acreages. The module shall also discuss the processes in several jurisdictions within Africa and how they vary from country-to-country. Students shall make presentations on the specifications in their country. b. CONTACT HOURS (SIX HOURS) The module shall be delivered in two classes of three hours each. This shall include the time used for presentations on country-to-country variations. AFP 110: Taxation of Hydrocarbon as well as Corporate Entities involved in Petroleum Production; Petroleum Operations under Concessions, Joint Ventures, Production Sharing Contracts, Sole Risk Agreements and Petroleum Production in the Deep Offshore, Offshore, Onshore and in Marginal Fields and the associated allowances, allowable deductions, ring fencing and royalty issues 35 a. AIM This module shall introduce students to emerging regulatory regimes for the distinct taxation of hydrocarbon as well as the distinct taxation of corporate operations of petroleum producing companies in Africa. Hitherto, in some tax regimes in Africa, companies involved in upstream petroleum production were not expected to be assessed distinctly for company income tax, however, under some emerging regimes they are statutorily required to pay company income tax. This issue shall be reviewed under this module. The module shall also treat the taxation of petroleum operations, by discussing its statutory meaning under Concessionary, Joint Venture, Production Sharing Contract and Sole Risk legal regimes. The module shall also expose students to the tax structure for deep offshore, offshore, onshore and marginal field production regimes. It shall also treat the tax allowances, allowable tax deductions and royalty regimes under the above production contract types. b. CONTACT HOURS (TWELVE HOURS) This module shall be delivered in four classes of three hours each. AFP 111: Gas Flare, Gas Re-injection, Gas - to - Liquid, Liquefied Natural Gas and Gas –to - Power Projects : Contractual, Regulatory and Tax Issues a. AIM This module shall introduce students to the issue of gas flares and gas related environmental issues in Africa. It shall further expose students to fiscal incentives for gas re-injection as well as the contractual issues pertaining to Gas-to-Liquid, Liquefied Natural Gas and Gas-to-Power projects and the issue of ownership and off-takers of 36 gas as well as the statutory role of the gas aggregator in several African gas jurisdictions. b. CONTACT HOURS (SIX HOURS) This module shall be delivered in six hours i.e. two days. AFP 112: Taxation of Solid Minerals Production and the investment incentives, tax allowances, allowable tax deductions and royalty issues a. AIM The aim of this module is to introduce students to the fiscal regime for the mining and the incentives for beneficiation of solid minerals in Africa. The module shall further introduce students to the differential fiscal regimes for mining of strategic economic minerals as distinct from luxury minerals in certain solid mineral jurisdictions. The module shall additionally expose students to the investment incentives, tax allowances, allowable tax deductions and royalty regimes for gas development in comparative African jurisdictions. [[[[[[ b. CONTACT HOURS (NINE HOURS) This module shall be delivered in three classes of three hours each. AFP 113: Taxation of Electricity and the ancillary investment incentives, tax allowances, allowable tax deductions and royalty issues a. AIM This module shall introduce students to the fiscal regime for electricity generation and distribution in comparative African regimes and the impact of the fiscal regime on the statutory role of the electricity aggregator as well as on the tariff for electricity. 37 The module shall also expose students to investment incentives, fiscal allowances, allowable fiscal deductions and royalty issues in several jurisdictions in Africa such as South Africa and Ghana. b. CONTACT HOURS (SIX HOURS) This module shall be delivered in six hours i.e. two days. AFP 114 : Investment Structuring for Petroleum, Mining and Electricity in Africa: Legal and Tax Framework for Private Equity, Venture Capital, Derivatives, Hedge Funds, BuyOuts, Carried Interest Schemes a. AIM This module shall introduce students to investment structuring that can be used for petroleum production, solid mineral mining and electricity generation in Africa. The module shall exhaustively treat the legal as well as fiscal regime for the afore-stated investment structures in South Africa as a best practice for consideration by other African countries. b. CONTACT HOURS (NINE HOURS) In view of the number of investment structures and the need to exhaustively discuss them, with comparative examples, the module shall be delivered in nine hours i.e. three days. AFP 115: Farm - In, Farm – Out, Acreage Transfer, Mergers and Acquisitions for Petroleum, Mining and Electricity Production and its ancillary legal framework for tax allowances, allowable tax deductions and royalty issues in Africa a. AIM The aim of this module is to introduce students to the legal framework for petroleum production, mining and electricity projects that require any of the afore-stated contractual financing modes as well as the legacy issues pertaining to tax and legal title that may arise. 38 b. CONTACT HOURS (NINE HOURS) In order to effectively treat the module, it shall be delivered in nine hours i.e. three days. AFP 116: Legal Framework for Petroleum, Mining and Electricity Project Finance (Debt Finance [Loans, Production Sharing, Modified Carry Arrangements], Mezzanine Finance, Corporate Bonds, Swaps, Securitization, Reserve Based Finance and Sukuk) in Africa. a. AIM This module shall expose students to the above contemporary and alternative structures for the funding of petroleum production, solid mineral mining and electricity in Africa. It is expected that at the end of the module, as well as all other modules, students would have acquired the required training in the subject matter(s). b. CONTACT HOURS (NINE HOURS) In view of the complexities of this module, students shall be taught over a period of nine hours i.e. three days. AFP 117: Arbitration of Petroleum, Mining and Electricity Contract Administration: Appraisal of the UNICITRAL Arbitration Rules, 2010 as well as the New York Convention on the recognition and Enforcement of Foreign Arbitral Awards vis-à-vis the arbitration legislations in African sample countries as it pertains to Petroleum and Solid Mineral Mining Production and Electricity Generation as well as the impact of several national legislations and how Pacta Sunt Servanda may be affected by Rebus Sic Stantibus in such transactions. a. AIM This module will therefore use case law such as the Tullow Case in Uganda, the IPCO and Agip Arbitrations in Nigeria to address the complex issues raised by investor-state arbitration, and in particular will address these issues in the context of disputes in the natural resources sector. Over a quarter of all investor-state arbitrations commenced in 2013 alone arose out of tax disputes related to oil, gas and mining projects such as in 39 Uganda and Nigeria. With the continued importance of natural resource exploitation to the wealth of many states, particularly in Africa, and a resurgence of resource nationalism in parts of the world, it is not unexpected that related disputes with foreign investors continue to figure prominently in investment treaty arbitration. b. CONTACT HOURS (SIX HOURS) This module shall be delivered in six hours i.e. two days. AFP 118: Managing Innovation and Transformation in Africa’s Growing Businesses: Legal and Tax Issues a. AIM b. CONTACT HOURS (SIX HOURS) This module shall be delivered in six hours i.e. two days. AFP 119: SUPERVISED ESSAY a. AIM Each student shall write a supervised essay of a minimum of four thousand, nine hundred (4,900) and a maximum of five thousand (5,000) words in double line, Times Roman. The word limit shall include footnotes. The topic of the essay must have been approved before commencement of the writing by the Registry. b. CONTACT HOURS (TWELVE HOURS) c. This module shall entail a cumulative time of twelve hours of students contact with their respective supervisors. 40
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