Operations Partner: InformaConnect Academy | Validation Partner: Middlesex University, London
HOW AUDITS, EVIDENCE AND LITIGATION SHAPE ARM’S LENGTH OUTCOME
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The Tax Court of Canada quashed appeals by Owens Corning Canada Holdings ULC after holding it lacked jurisdiction to order a downward transfer pricing adjustment sought in the calculation of
The Swedish Supreme Administrative Court set aside lower-court decisions that had applied the transfer-pricing correction rule to deny Kubikenborg Aluminium AB a deduction for damages paid to Vattenfall following early
The Swedish Supreme Administrative Court set aside lower-court decisions that had applied the transfer-pricing correction rule to deny Kubikenborg Aluminium AB a deduction for damages paid to Vattenfall following early
The French Conseil d’État rejected the Minister’s cassation appeal against the Paris Administrative Court of Appeal’s decision granting partial relief to Engie (formerly GDF Suez) in a transfer pricing dispute
The French Conseil d’État rejected the Minister’s cassation appeal against the Paris Administrative Court of Appeal’s decision granting partial relief to Engie (formerly GDF Suez) in a transfer pricing dispute
Brexit significantly reshaped the UK’s treaty network, impacting trade, tax, investment, and financial services agreements. This video explores the question in detail.
Explore how being part of the European Union but not the OECD impacts treaty negotiations. This video discusses the influence of EU directives on tax treaties, the limitations faced by
Discover the complex dynamics involved when international conflicts or sanctions impact existing treaties. This video provides detailed insights into treaty suspension, termination, and renegotiation processes governed by the Vienna Convention
In this video, we explore the challenges of applying arm’s length pricing in the diamond industry, evaluate methods like TNMM, RPM, PSM, and CUP, and provide insights into selecting
Dive into the complexities of the Canada v. GlaxoSmithKline Inc. transfer pricing dispute, a landmark case that examines the use of the Resale Price Method (RPM) versus the Comparable Uncontrolled
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Choose the track that fits your practice focus. All programmes are practitioner-taught, cohort-based, and validated by Middlesex University.
| Dimension | Transfer Pricing | International Taxation | South African Tax Law |
|---|---|---|---|
| Jurisdictional audience | Global audience, covers all jurisdictions | Global audience, covers all jurisdictions | South Africa specific, relevant to SADC region |
| Ideal for | TP managers, advisors, in-house tax teams, analysts moving into TP | Advisors and managers dealing with cross-border rules, treaties, planning | Practitioners working with the SA Income Tax Act, cases, compliance |
| Core focus | Methods, comparables, DEMPE, documentation, audits, dispute defence | Treaties, source vs residence, anti-avoidance, PE, relief from double tax | Statutory interpretation, case law, assessments, objections, local practice |
| Primary tools | OECD TP Guidelines, UN Manual, BEPS Actions 8–10, 13, case law | OECD and UN Models, MLI, BEPS 1.0 and 2.0, domestic rules, cases | Income Tax Act, SARS practice notes, Tax Administration Act, SA cases |
| Assessment style | Case-based assignments, file reviews, short written defences | Problem questions, treaty interpretation, position papers | Problem questions, statutory analysis, case commentary |
| Typical outcomes | Build defensible TP files and strategies, improve audit readiness | Design cross-border structures within rules, mitigate double tax | Apply SA tax law accurately, manage reviews and disputes |
| Entry point | Start with PG Certificate, progress to PG Diploma, then MSc, or enter later with suitable experience or credits. | ||
| Award | Best for | What you achieve | Assessment highlights |
|---|---|---|---|
| PG Certificate | Foundation to intermediate upskilling | Core concepts, frameworks, and applied techniques | Short case write ups, timed responses, applied tasks |
| PG Diploma | Expanding technical depth and application | Advanced analysis, risk management, documentation quality | Integrated case assignments, policy memos, oral defence |
| MSc | Leaders and specialists building authority | Capstone project and research backed practice outcomes | Research project, viva or presentation, publishable summary |
Practical, practitioner-led certificates designed for immediate on-the-job application. Each course can stand alone or act as a pathway into our postgraduate tracks.
| Dimension | Conducting a Transfer Pricing Trial | Effectively Managing Tax Teams | Indirect Taxation | Tax Risk Management |
|---|---|---|---|---|
| Jurisdictional audience | Global audience | Global audience | Global audience, with local adaptation | Global audience |
| Ideal for | In-house tax, TP managers, litigators, advisors preparing for audits, ADR, trial | Heads of tax, managers, team leads, controllers, emerging leaders | VAT, GST, customs, finance managers, AP, AR, compliance specialists | Tax managers, risk officers, controllers, advisors building governance |
| Core focus | Case theory, evidence files, expert reports, witness prep, courtroom strategy | Operating models, KPIs, workflows, stakeholder management, coaching | VAT design, place of supply, input credits, exemptions, WHT interactions | Risk identification, controls, documentation, audit readiness, dispute playbooks |
| Delivery mode | Online, live sessions plus guided self-study | Online, live sessions plus guided self-study | Online, live sessions plus guided self-study | Online, live sessions plus guided self-study |
| Duration | 16 weeks, part-time | 16 weeks, part-time | 16 weeks, part-time | 16 weeks, part-time |
| Outcomes | Confident litigation preparation and defence for TP disputes | Stronger execution, clear roles, measurable team performance | Reduced VAT errors, better cash flow, fewer surprises at audit | Structured governance, fewer findings, faster dispute resolution |
| Prerequisites | TP fundamentals recommended | Supervisory experience helpful | Basic VAT knowledge helpful | General tax experience helpful |
| Pathway | Progress to PG Certificate in Transfer Pricing | Progress to Mechanics of Leading Tax Teams, PG Certificate (leadership) | Progress to PG programmes, International Tax or SA Tax Law | Progress to PG Certificate in International Taxation or Transfer Pricing |
| Assessment | End of module progress assessment 5000-word assignment if PG-Cert option elected |
End of module progress assessment 5000-word assignment if PG-Cert option elected |
End of module progress assessment 5000-word assignment if PG-Cert option elected |
End of module progress assessment 5000-word assignment if PG-Cert option elected |