atl_logo_white_png_RETINA
atl_logo_white_png_RETINA
Main Menu

Latest Tax Posts

Articles | Cases | Research

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.

Continue Reading »
ARCHIVED POSTS

India vs Xchanging Solutions Limited, April 2026, Income Tax Appellate Tribunal, Case No 385/Bang/2025

ATL-Editor 5 June 2026

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.

Continue Reading »

Portugal vs “A Wide Range, LDA”, April 2026, Supremo Tribunal Administrativo, Case No 01721/10.5BEPRT.SA1

ATL-Editor 5 June 2026

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.

Continue Reading »

Italy vs SATA Sud S.p.A., April 2026, Supreme Court, Case No 10456/2026

ATL-Editor 5 June 2026

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.

Continue Reading »

Italy vs NN Europe S.p.A., May 2026, Supreme Court, Case No 13136/2026

ATL-Editor 5 June 2026

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.

Continue Reading »

India vs American Express (India) Pvt. Ltd., May 2026, High Court of Delhi, Case No ITA 656/2019

ATL-Editor 5 June 2026

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.

Continue Reading »

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.

Continue Reading »
Shopping Cart
Scroll to Top

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