In Canada (National Revenue) v. Thompson, the Supreme Court of Canada evaluated the boundary between solicitor-client privilege and the statutory obligations imposed on lawyers under the Income Tax Act (ITA).
In Case C-694/20, the European Court of Justice (ECJ) examined the legality of certain reporting obligations imposed on lawyers under Council Directive 2011/16/EU (as amended by Directive 2018/822).
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.
This case involves the European Commission’s ruling that Luxembourg’s tax rulings for ENGIE constituted unlawful state aid, creating tax advantages that contravened the competitive balance required under EU law.
ENGIE vs EU: State Aid Decision in the EU’s Effort to Combat Selective Tax Advantages Read Post »
In this insightful address at the 13th Annual Africa Transfer Pricing Summit, Dr. Daniel N Erasmus explores the most pressing trends in transfer pricing across Africa and developing regions.
The Comparable Profit Method (CPM) is a widely used approach in transfer pricing, employed to ensure that transactions between related entities (often within multinational enterprises) align with the arm’s length principle.
Understanding the Comparable Profit Method (CPM) in Transfer Pricing Read Post »
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.
Hyatt vs India (ADIT) tackles several pivotal issues regarding the attribution of income to a Permanent Establishment (PE) in India, even in cases where the global entity has incurred financial losses.
Hyatt International vs. India (ADIT) Read Post »
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 Income Tax Appellate Tribunal (ITAT), Delhi Bench, ruled in favour of General Motors USA in a case revolving around the Double Taxation Avoidance Agreement (DTAA) between India and the USA. The core issue concerned whether the assessee, an LLC, could be considered a “resident” for tax purposes under Article 4 of the India-USA DTAA
General Motors v. ACIT, Circle International Taxation 1(3)(1), New Delhi Read Post »
Permanent Establishments (PEs) play a crucial role in the realm of transfer pricing, as they serve as the bridge between international taxation and multinational enterprise (MNE) operations. As global trade becomes increasingly interconnected, understanding how PEs influence transfer pricing has become essential for tax professionals and multinationals alike.
Understanding the Role of Permanent Establishments in Transfer Pricing 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 »
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 |