The importance of financial data and calculations in transfer pricing documentation cannot be overstated. Accurate financial information forms the backbone of any robust transfer pricing analysis, ensuring compliance with tax regulations and mitigating risks associated with cross-border transactions.
Importance of Financial Data and Calculations in Transfer Pricing Documentation Read Post »
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 »
Transfer pricing continues to be a critical issue for multinational corporations. The resale price method (RPM) plays a significant role in many high-profile cases. This article examines the importance of RPM in four major transfer pricing disputes and offers insights for better managing these risks.
The Resale Price Method in Major Transfer Pricing Cases Read Post »
Intercompany agreements and contracts are critical elements in transfer pricing, ensuring that transactions between related entities within a multinational enterprise (MNE) comply with the arm’s length principle.
Intercompany Agreements and Contracts in Transfer Pricing Documentation Read Post »
The Dow Chemical Canada case underscores the complex interplay between tax law, administrative discretion, and jurisdictional issues in transfer pricing disputes.
Dow Chemical Canada ULC v. The King: Tax Court Jurisdiction in Transfer Pricing Disputes Read Post »
The Federal Court of Australia’s judgment in PepsiCo, Inc v Commissioner of Taxation provides critical insights into the characterization of payments under intercompany agreements and the application of tax laws.
PepsiCo v Australia: Implications for Royalty Withholding Tax and Diverted Profits Tax Read Post »
The Keysight Technologies Malaysia case underscores the complexities of transfer pricing and tax compliance. By understanding the court’s findings and implementing robust tax risk management strategies, companies can better navigate similar disputes and ensure compliance with tax regulations.
Keysight Technologies v. Malaysia: Implications for Transfer Pricing and Tax Compliance 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 Malaysian transfer pricing case of Watsons Personal Care Stores vs tax authorities, its implications for multinationals, and key takeaways.
Malaysia Transfer Pricing Case: Watsons Personal Care Stores vs Tax Authorities Read Post »
The Transactional Net Margin Method (TNMM) is a pivotal tool in transfer pricing, used to ensure that transactions between associated enterprises are conducted at arm’s length. This method compares the net profit margin of a taxpayer from a controlled transaction with that of comparable uncontrolled transactions.
Understanding the Transactional Net Margin Method (TNMM) in Transfer Pricing Read Post »
The Cost Plus Method is a widely used approach in transfer pricing for determining arm’s length prices between related entities. This method is particularly useful for manufacturers, service providers, and other businesses that add value to goods or services before transferring them to related parties.
The Cost Plus Method in Transfer Pricing Read Post »
The Comparable Uncontrolled Price (CUP) Method is one of the primary transfer pricing methods used to determine arm’s length prices for transactions between related entities.
Understanding the Comparable Uncontrolled Price (CUP) Method in Transfer Pricing 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 |