Discover the primary advantage of a negotiated transfer price and its impact on multinational enterprises. Learn why consulting TRM is essential for effective management.
The Primary Advantage of Negotiated Transfer Pricing Read Post »
Discover strategies at the GTC Conference 2024 on creating a controversy roadmap for MNEs. Join us in Milan or online on June 7, 2024.
Join Us at the GTC Conference 2024 in Milan: Mastering Controversy Roadmaps for MNEs Read Post »
Join our free workshop on transfer pricing trials led by Prof Dr Daniel N Erasmus. Gain insights and strategies for managing royalty rate disputes.
WORKSHOP: Conducting a Transfer Pricing Trial Read Post »
Explore the critical insights from the Tresping Manufacturing vs. SARS case on navigating tax disputes and compliance with customs regulations.
Tax Dispute Resolutions: A Case Study on Tresping Manufacturing vs. SARS Read Post »
TRM Tax Attorneys secures landmark victory in South Africa’s first transfer pricing case, demonstrating expertise in resolving complex tax disputes. Learn how Prof Dr Daniel N Erasmus and his team can assist you.
Landmark Transfer Pricing Case from South Africa Read Post »
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 »
Explore how TRM’s expertise in transfer pricing challenges in South Africa helped ABD Limited win against SARS, offering insights for multinationals.
South Africa’s First Transfer Pricing Case Read Post »
Can we hear a “woohoo”!? Yes, you read right, South Africa has finally had its first TP case and whaddaya know, the taxpayer won!
South Africa’s first Transfer Pricing case, and it’s a win for the taxpayer! Read Post »
Explore the critical analysis of the transfer pricing dispute judgment between ABD Limited and SARS, focusing on IP royalties and tax implications.
ABD Limited vs. SARS Transfer Pricing Dispute Judgment Read Post »
This workshop was designed to give aspiring and practising tax professionals an overview of what is needed to navigate the complex terrain of tax audits, assessments, objections, appeals, tax board hearings, and emerging developments in tax legislation in South Africa.
DID YOU MISS THE MASTERING TAX DISPUTE RESOLUTION IN SOUTH AFRICA WORKSHOP? Read Post »
The recent approval by the OECD Council of the OECD Model Tax Convention Update 2024 marks a pivotal moment for international tax practitioners and multinational organizations
Article 26 of the OECD Model Tax Convention Update 2024 Read Post »
Join us for a critical online workshop, Quo Vadis VAT in a Digitalised World: The Need for Multilateral Coordination, on Wednesday, 28 February, at 14:00 GMT. This complimentary session, led by expert Robert van Brederode, addresses the evolving challenges VAT faces in our digital economy.
Exclusive Workshop Invite: Navigating VAT in the Digital Economy 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 |