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Tanzania vs Total Tanzania Limited, April 2026, Court of Appeal, Case No Civil Appeal No 425 of 2023

ATL-Editor 12 June 2026

The Court of Appeal of Tanzania quashed the decisions of the Tax Revenue Appeals Board and the Tax Revenue Appeals Tribunal in a dispute over the deductibility of group technical assistance fees paid by Total Tanzania Limited to Total Outre Mer. The court held that the Board’s judgment was fatally defective because the Vice Chairman had failed to record reasons for disagreeing with a dissenting member’s opinion, as required by rule 15(3) of the Tax Revenue Appeals Board Rules, 2018.

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Italy vs Illva Saronno SpA, May 2026, Supreme Court, Case No 15698/2026

ATL-Editor 5 June 2026

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.

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India vs Inductotherm (India) Pvt. Ltd., May 2026, Income Tax Appellate Tribunal, Case No ITA No. 1609/Ahd/2024

ATL-Editor 5 June 2026

The Income Tax Appellate Tribunal, Ahmedabad allowed the appeal of Inductotherm (India) Pvt. Ltd. for statistical purposes, directing deletion of a transfer pricing adjustment of Rs.3,88,46,904 and remanding two further issues to the Assessing Officer for fresh adjudication. The Tribunal held that TNMM at entity level was the most appropriate transfer pricing method, consistent with coordinate bench decisions in the assessee’s own case for earlier assessment years.

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Portuguese Supreme Court Rejects Free Capital Transfer Pricing

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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Canada vs Owens Corning Canada Holdings ULC, March 2026, Tax Court, Case No. 2026 TCC 60

ATL-Editor 30 May 2026

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 foreign accrual property income. The court found that such adjustments require the Minister’s discretionary approval under subsection 247(10) of the Income Tax Act and cannot be ordered by this Court.

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Swedish Court Rejects Tax Challenge to Electricity Contract Damages

ATL-Editor 30 May 2026

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 termination of an electricity agreement. The court held that the conditions for applying the correction rule were not satisfied because no income had been transferred from Kubal to its parent, Rusal, within the meaning of the rule.

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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