The Academy of Tax Law is excited to announce an online Transfer Pricing Conference specifically emphasising Africa. This event will […]
Announcement: Online Transfer Pricing Conference Focused on Africa Read Post »
Dr. Daniel N Erasmus, a leading expert in international tax law and transfer pricing, will be a key speaker at the upcoming Online Transfer Pricing Conference Africa 2024.
The Academy of Tax Law is excited to announce an online Transfer Pricing Conference specifically emphasising Africa. This event will take place in November 2024 and will delve into global transfer pricing issues.
Announcement: Online Transfer Pricing Conference Focused on Africa Read Post »
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.
The X BV v Staatssecretaris van Financiën case revolves around a key issue in corporate tax: the denial of interest deductions for intra-group loans in cross-border transactions.
X BV v Netherlands (Staatssecretaris van Financiën Case) Read Post »
This case involves a dispute over the deductibility of financial costs related to loans taken out by the taxpayer (A…, Sociedade Unipessoal, LDA) to finance the acquisition of a 70% shareholding in a related company (C…). The Portuguese Tax Authority (AT) disallowed the deduction, arguing that these financial costs were not indispensable for generating taxable income.
Sociedade Unipessoal, LDA vs Portugal Read Post »
The Wisconsin Tax Appeals Commission ruled in favour of the Wisconsin Department of Revenue, affirming its disallowance of royalty deductions claimed by Skechers USA Inc. in relation to intercompany transactions between Skechers and its subsidiary, Skechers USA Inc. II
Skechers USA Inc. vs. USA Read Post »
The dispute focused on the income tax treatment of intellectual property (IP) transactions between 3M’s U.S. subsidiaries and its Brazilian subsidiary, 3M do Brasil Ltda (3M Brazil), for the tax year 2006.
The case revolved around whether Nokia Solutions and Networks Oy had a Permanent Establishment (PE) in India, and whether profits could be attributed to that PE under the India-Finland Double Taxation Avoidance Agreement (DTAA).
Nokia vs. India: Permanent Establishment and Profit Attribution Dispute Read Post »
The case involves two appeals by Fiat Chrysler Finance Europe (formerly Fiat Finance and Trade Ltd) and Ireland, challenging the General Court’s decision to uphold a European Commission ruling that a tax ruling granted by Luxembourg to Fiat Chrysler Finance Europe constituted unlawful state aid.
ITB is a weekly PodCast by Steve Towers. It covers all major global tax events for any given week. 07
International Tax Bytes: 7 October 2022 Read Post »
The BESPOKE-winning methodology that we teach in our Postgraduate course in Transfer Pricing and International taxation has been tried and
I/I/T/F METHODOLOGY = SUCCESSFUL CASES 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 |