Articles | Cases | Research
A bank appealed against SARS’s disallowance of input VAT deductions totalling R5 551 275.52 arising from a cashback scheme under which monthly banking fees previously charged to clients were credited back to qualifying clients. The Tax Court upheld the appeal, finding that the credits constituted an alteration of the previously agreed consideration as contemplated in section 21(1)(c) of the VAT Act 89 of 1991.
The Court of Appeal dismissed HMRC’s appeal against the Upper Tribunal’s decision that approximately £90.8 million of post-administration interest received by an Irish-resident investment company on a purchased debt claim in the Lehman Brothers International (Europe) administration was exempt from UK withholding tax under Article 12(1) of the UK-Ireland double taxation treaty. The court held that neither the seller nor the buyer had a main purpose of ‘taking advantage of’ Article 12(1) within the meaning of the treaty’s anti-abuse provision, Article 12(5).
The Paris Administrative Court of Appeal upheld a tax reassessment against SARL Calliope, finding that the company had indirectly transferred profits to its Italian parent-group companies in breach of Article 57 of the French General Tax Code. The court rejected all grounds of appeal and dismissed the company’s request for reinstatement of its carry-forward deficit and discharge of additional taxes.
Lifeplus Europe Ltd successfully appealed against an HMRC information notice requiring it to produce its US parent company’s consolidated and entity-level financial statements for accounting periods ending 31 December 2014 to 31 December 2022. The First-tier Tribunal held that the documents were neither reasonably required to check the appellant’s corporation tax position nor within the appellant’s possession or power.
Brazil’s CARF upheld the cancellation of a transfer-pricing adjustment levied on PETROBRAS in respect of oil-platform charter fees for the 2019 calendar year, finding that the tax authority could not use the initial contract term as a proxy for the investor’s expected return period. The tribunal also upheld the simultaneous imposition of an isolated penalty for unpaid monthly IRPJ and CSLL estimates alongside the annual-adjustment penalty.
The Italian Supreme Court dismissed La Termoplastic F.B.M. s.r.l.’s appeal against a tax assessment for the 2010 tax year, upholding adjustments to intra-group transfer prices and disallowing deductions for leasing instalments on contracts shorter than the statutory minimum duration. The court confirmed that the transactional net margin method was properly applied and that no retroactive relief was available in respect of the leasing rules.
ExxonMobil Canada Resources Company appealed the disallowance of a $36,207,810 deduction for Alaskan gas pipeline feasibility study costs and a related Part XIII tax assessment of $1,810,391. The Tax Court of Canada allowed the appeal in full, holding that the costs were deductible as business expenses and that the transfer pricing and Part XIII provisions did not apply.
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 |