This case focuses on whether the Netherlands’ national tax law, which restricts the deduction of interest paid on intra-group loans in certain scenarios, is compatible with the freedom of establishment under Article 49 TFEU.
The CJEU’s judgment of 10 September 2024 overturned the General Court’s previous ruling, confirming that Ireland’s tax rulings to Apple Sales International (ASI) and Apple Operations International (AOI) provided an unfair advantage.
European Commission vs Apple and Ireland (Appeal) Read Post »
The General Court of the European Union ruled in favour of Luxembourg and Amazon, annulling the European Commission’s decision that Luxembourg granted illegal state aid to Amazon through tax rulings.
General Court Judgment in Amazon and Luxembourg v European Commission Read Post »
In August 2024, the Italian Supreme Court delivered a pivotal ruling on transfer pricing, specifically addressing the inclusion of loss-making entities in comparability analyses. This ruling could hopefully show a significant shift in how transfer pricing is approached, emphasizing a more comprehensive and accurate reflection of market realities.
The Italian Supreme Court’s Landmark Ruling on Loss-Making Entities: My Take Read Post »
The Italian Supreme Court’s 2024 ruling mandates including loss-making entities in transfer pricing comparability analysis, aligning with OECD guidelines.
The judgment in the case C-623/22, issued by the Court of Justice of the European Union (CJEU) on July 29, 2024, primarily addressed the validity of certain provisions of Directive 2011/16/EU as amended by Directive 2018/822, concerning the mandatory automatic exchange of information on reportable cross-border tax arrangements.
Intra-group losses in transfer pricing have become a focal point of legal scrutiny and regulatory enforcement. The recent cases of Dart Sudamericana, ST Dupont, and Stora Enso highlight the complexities and challenges multinational enterprises (MNEs) face in justifying and managing these losses.
Understanding Intra-Group Losses in Transfer Pricing: Key Insights from Recent Cases Read Post »
Explore non-recognition in transfer pricing through landmark cases from Malaysia, Luxembourg, and Denmark. Expert analysis by Prof. Dr. Daniel N. Erasmus.
Understanding Non-Recognition in Transfer Pricing Read Post »
Summary of the Danish Supreme Court’s landmark ruling on transfer pricing in the Maersk Oil case, with implications for multinationals and tax authorities worldwide.
Danish Supreme Court Upholds Transfer Pricing Adjustment in Maersk Oil Case Read Post »
Luxembourg court rules interest-free loan qualifies as debt, allowing notional interest deduction in landmark transfer pricing case with implications for multinationals.
Analysis of Dutch court ruling on arm’s length principle in intra-group financing. Key insights for multinationals on transfer pricing and tax risk management.
Analysis of the ERT Automotive Bohemia case emphasizses the critical role of the burden of proof in transfer pricing disputes and its implications for multinationals.
Czech Transfer Pricing Case Highlights Importance of Burden of Proof 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 |