The Court of Justice ruled on whether transfer price adjustments made between intra-group motor vehicle companies constituted consideration for a VAT-liable supply of repair services. It held that such adjustments do not constitute consideration for a supply of services for VAT purposes unless a direct legal relationship of reciprocal performance can be established between the parties.
A Luxembourg-registered company, Coupole Finance, was found to have its effective management and a permanent establishment in France and was assessed to corporate income tax and VAT for the years 2003 to 2010, together with an 80% penalty for concealed activity. The Administrative Court of Appeal of Nantes dismissed the company’s appeal against those assessments.
The Italian Supreme Court quashed the Regional Tax Commission’s ruling that intragroup service costs charged to KAI S.r.l. (formerly Shell Italia Aviazione) were fully deductible, holding that the lower court had applied insufficiently rigorous standards of proof of effective utility. The court also rejected the taxpayer’s cross-appeal seeking cross-period compensation for costs deducted in the wrong tax year.
The Portuguese Supreme Administrative Court dismissed the tax authority’s appeal and annulled an additional IRC assessment for the 2006 tax year, holding that Article 58 of the CIRC did not authorise the recharacterisation of part of a branch’s intercompany loans as free capital in order to disallow the corresponding interest deduction. No provision of Portuguese domestic law or the Portugal-France double tax convention applicable at the time supported that recharacterisation.
Portugal’s Top Court Blocks Free Capital Adjustment on Legal Grounds Read Post »
The Court of Appeal of Tanzania dismissed an appeal by Amadeus Global Travel Distribution Limited against a tax assessment for the 2015 year of income, upholding the inclusion of finance costs in the computation of taxable revenue under the Transactional Net Margin Method. The court held that the appellant’s challenges were substantially questions of fact and evidence evaluation over which it lacked jurisdiction under section 25(2) of the Tax Revenue Appeals Act.
The Income Tax Appellate Tribunal, Bangalore partly allowed an appeal by Xchanging Solutions Limited for assessment year 2011-12, directing the assessing officer to exclude five comparables from the arm’s length price computation for software development services. The Tribunal found that an earlier ITAT direction to the Dispute Resolution Panel to reconsider those comparables had not been complied with in time.
The Supremo Tribunal Administrativo admitted an exceptional review appeal brought by a Portuguese company challenging an additional IRC assessment for the year 2004, which arose from a transfer pricing correction made by the tax authorities. The court held that the questions raised concerning the transfer pricing regime were of fundamental legal and social importance and that its intervention was necessary for a better application of the law.
The Italian Supreme Court allowed the tax authority’s appeal concerning the deductibility for IRAP purposes of intra-group consultancy costs of euro 211,804.28 charged at a flat rate of 1.75% of monthly sales. The court held that the lower court had misallocated the burden of proof and that a formal contract and absence of qualified staff were insufficient, without proof of the specific services actually performed in the relevant tax period.
Italy vs SATA Sud S.p.A., April 2026, Supreme Court, Case No 10456/2026 Read Post »
The Italian Supreme Court dismissed the tax authority’s appeal and held that transfer pricing rules do not apply to an intra-group guarantee provided without remuneration where valid commercial reasons for the transaction are established. The court confirmed that the taxpayer had discharged its burden of proving such reasons, including the risk to the Italian subsidiary’s survival had the parent company entered insolvency.
Italy vs NN Europe S.p.A., May 2026, Supreme Court, Case No 13136/2026 Read Post »
The Delhi High Court decided a Revenue appeal concerning transfer pricing adjustments for Assessment Year 2009-10 in the case of a captive IT-enabled services provider. The court admitted two of seven proposed substantial questions of law and answered both in favour of the Revenue, directing the Transfer Pricing Officer to examine the functional comparability of Cepha Imaging Pvt. Ltd. and to exclude CG Vak Software and Exports Ltd. on account of an extreme turnover disparity.
The Italian Supreme Court partly upheld a transfer pricing appeal by Illva Saronno SpA and Illva Saronno Holding SpA, quashing the regional tax court’s ruling on the choice of transfer pricing method and remitting the case for fresh examination. The court rejected the taxpayers’ grounds on procedural fairness, burden of proof and omitted historical facts.
Italy vs Illva Saronno SpA, May 2026, Supreme Court, Case No 15698/2026 Read Post »
The Supreme Court of India dismissed the tax authority’s Special Leave Petition challenging a Delhi High Court ruling in favour of Pernod Ricard India Private Limited, on grounds of both delay and lack of merit. The petition was filed 384 days late and the Court found no good ground to interfere with the High Court’s order.
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 |