This article was published by South African Revenue Service and the full article is available at: https://www.sars.gov.za/individuals/what-if-i-do-not-agree/being-audited-or-selected-for-verification/ What is verification? […]
SARS – Being Audited or Selected for Verification Read Post »
Article by: Regan van Rooy Movie buffs will hopefully get the joke intended in this week’s newsletter title, however, if
Risky Business – 10 things I hate about TP! Read Post »
The Academy of Tax Law would like to congratulate the head of our academics, Dr Daniel N. Erasmus, and his
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The case of Medtronic, Inc. vs. Commissioner of Internal Revenue revolves around the complex issue of transfer pricing, particularly concerning the appropriate method to determine the arm’s length royalty rates for the use of intellectual property between Medtronic US and its Puerto Rican subsidiary, MPROC.
Medtronic vs Commissioner of Inland Revenue Read Post »
GTC Conference 2022 The introduction of BEPS has changed the landscape of international taxation. It brought about not only legislative
DOWNLOAD THE FULL SUMMARY IN PDF HERE VIEW THE FULL JUDGMENT HERE Case Information Court: Østre Landsret Case No: BS-12642/2020
BY: Mark Korten – Korten Consulting The Minister of Finance in Mauritius presented the 2020/21 Budget on 11 June 2021. I
2020/21 Mauritius Budget Read Post »
Article by: Quebiko.com Now you are able to take the most inclusive Transfer Pricing courses at great pricing on either
Transfer Pricing Masterclass Read Post »
Article by: Udo Udoma & Belo-Osagie Overview Prior to 2012, there was no comprehensive law regulating transfer pricing in Nigeria.
Transfer pricing in a nutshell: Nigeria Read Post »
Article by: Dr Daniel N Erasmus (Pieterse TRM Erasmus Tax Attorneys) SARS is circulating a section 46 of the Tax
Article by: Fotodotis Malamas (Bernitsas Law) Accepted methods What transfer pricing methods are acceptable? What are the pros and cons
Transfer pricing methods in Greece Read Post »
Article by: Eyal Bar-Zvi (Herzog Fox & Neeman) Overview Israel’s transfer pricing regime is regulated under Section 85A (Section 85A)
Transfer pricing in a nutshell: Israel Read Post »
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 |