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Sweden vs “SE AB”, April 2026, Administrative Court of Appeal in Jönköping, Case Nos 2794-23 and 2795-23

ATL-Editor 24 June 2026

A Swedish Administrative Court of Appeal partially upheld a company’s appeal against transfer pricing adjustments for tax years 2017 and 2018, finding that the Swedish Tax Agency had not discharged its burden of proof for restricting the arm’s length range to the interquartile range where the comparables set contained only ten companies. The court reduced the company’s taxable business income accordingly and halved the tax surcharges on grounds of unreasonably long processing time.

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Netherlands vs “X Hybrid B.V.”, May 2026, Supreme Court, Case No 21/04746 (ECLI:NL:HR:2026:736)

ATL-Editor 6 June 2026

The Dutch Supreme Court upheld the denial of interest deductions on loans used to finance a hybrid cross-border joint-venture structure, finding that neither the compensating-levy safe harbour nor EU law prevented application of the counter-counter-evidence rule under Article 10a of the Wet Vpb 1969 and the doctrine of fraus legis. All four grounds of the principal cassation appeal were dismissed.

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Portugal vs Stellantis Portugal S.A., May 2026, European Court of Justice, Case No C-603/24

ATL-Editor 5 June 2026

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.

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France vs Coupole Finance, March 2026, Administrative Court of Appeal of Nantes, Case No 25NT01793

ATL-Editor 5 June 2026

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.

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Italy vs KAI S.r.l. (Shell Italia Aviazione), March 2026, Supreme Court, Case No 5753/2026

ATL-Editor 5 June 2026

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.

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Portugal’s Top Court Blocks Free Capital Adjustment on Legal Grounds

ATL-Editor 5 June 2026

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.

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Tanzania vs Amadeus Global Travel Distribution Limited, March 2026, Court of Appeal, Civil Appeal No. 227 of 2025

ATL-Editor 5 June 2026

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.

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Compare Programmes

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.

Awards Ladder

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

IFF Certificate Courses

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