The Supreme Court of Appeal of South Africa (SCA) ruled against Christoffel Hendrik Wiese and other appellants in their appeal concerning SARS’s efforts to recover a tax debt under section 183 of the Tax Administration Act (TAA).
RSA vs Wiese & Others: TAX DEBT RECOVERY CASE Read Post »
This case, decided by the Federal Court of Australia on 30 November 2023, addressed key taxation issues involving royalty withholding tax and diverted profits tax in the context of multinational enterprises (MNEs).
Australia vs PEPSICO: TRANSFER PRICING CASE Read Post »
This case addressed Oracle Corporation Australia Pty Ltd’s application to temporarily stay domestic court proceedings while a Mutual Agreement Procedure (MAP) under the Australia-Ireland double taxation treaty was ongoing. The case revolved around whether payments made by Oracle Australia to Oracle Ireland for sublicensing software were “royalties” under the treaty and thus subject to Australian withholding tax obligations.
Australia vs Oracle: Transfer Pricing Case Read Post »
This case examines the boundaries of judicial review in tax disputes involving the Diverted Profits Tax (DPT), a tax introduced by the Finance Act 2015 to prevent profit shifting by multinationals. Glencore Energy UK Limited (GENUK), a subsidiary of the Swiss-based Glencore International AG (GIAG), was assessed under the DPT framework after HMRC deemed the service fees paid by GENUK to GIAG under a Risk and Services Agreement (RSA) to be excessive.
UK vs Glencore Energy: Transfer Pricing Case Read Post »
The case of Canada v. General Electric Capital Canada Inc. (2010 FCA 344) revolved around whether guarantee fees paid by GE Canada to its parent company, GECUS, adhered to the arm’s length principle under Canadian tax law. GE Canada claimed deductions for these fees in its income calculations for the 1996–2000 taxation years.
Canada vs General Electric Capital Canada: Transfer Pricing Case Read Post »
The Court of Appeal’s decision in Refinitiv v HMRC is a defining moment in the intersection of transfer pricing and Diverted Profits Tax (DPT). The case revolved around DPT notices issued to three UK-resident companies within the Thomson Reuters group for the 2018 tax period, totaling over £167 million.
UK vs REFINITIV AND OTHERS (Thomson Reuters): Transfer Pricing Case Read Post »
The Minebea Slovakia transfer pricing case highlights the intricate challenges of aligning intra-group transactions with arm’s length principles. In this landmark ruling, the Supreme Administrative Court of Slovakia dismissed a cassation complaint filed by Minebea Access Solutions Slovakia s.r.o., a subsidiary of the Valeo Group.
Slovakia vs Minebea Access Solutions: Transfer Pricing Case Read Post »
The Italy v. Ilapark SPA case brings forward critical issues in transfer pricing, specifically the appropriateness of the selected transfer pricing method for a business entity under Italy’s tax framework and its alignment with OECD guidelines.
Italy v. Ilapak SPA Transfer Pricing Case Read Post »
In Boerdery v SARS, the South African Tax Court addressed whether premiums paid by Boerdery under insurance contracts with Company XYZ were deductible under section 11(a) of the Income Tax Act. Boerdery claimed the premiums as deductible expenses, arguing they represented insurance costs necessary for its farming business.
Insights from Boerdery v SARS: Assessing Deductibility of Premiums in Farming Read Post »
The case Commissioner of Taxation v. SNF (Australia) Pty Ltd concerned a dispute over the application of the arm’s length principle in the context of transfer pricing regulations under Australia’s Income Tax Assessment Act 1936 (ITAA 1936)
Australia vs SNF: In-Depth Summary Read Post »
The High Court of Australia deliberated on a significant transfer pricing case between Singapore Telecom Australia Investments Pty Ltd (STAI) and the Commissioner of Taxation, centering on whether a parental guarantee should be implied in assessing the arm’s length nature of intercompany loans.
Australia vs SingTel Transfer Pricing Case Read Post »
In the landmark case of The Thistle Trust v Commissioner for the South African Revenue Service, the Constitutional Court of South Africa was tasked with examining the application of the conduit principle in the taxation of trusts, particularly focusing on how capital gains are treated within a multi-tiered trust structure.
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 |