Raising jurisdictional issues Cliffe Dekker Hofmeyr South Africa April 13 2018 Where a taxpayer is dissatisfied with the decision taken by […]
S.Africa Tax Court and Appeals: Raising jurisdictional issues Read Post »
Download a copy here: US TP 2018 Coca Cola case petitioner’s pre-trial memorandum To understand the applicable TP principles applicable
US TP the pre-trial memorandum in the Coca-cola intangibles case and various articles Read Post »
The defective SARS Notice of Intention to Appeal: REDACTED Appeal intention and TAA provisions_Redacted DRAFT application to the High Court:
SARS issues new guide to understatement penalties – a march toward further certainty? Cliffe Dekker Hofmeyr April 6 2018 The
SARS issues new guide to understatement penalties – a march toward further certainty? Read Post »
Explore our detailed analysis of the Zimmer Ltd. vs. Germany (2018) case. Learn how this ECJ judgment impacts the definition of Permanent Establishment and international tax compliance.
In GlaxoSmithKline (GSK) Philippines, Inc. v. Commissioner of Internal Revenue (CIR), the Supreme Court of the Philippines upheld a tax deficiency assessment against GSK Philippines, emphasizing the importance of adhering to transfer pricing regulations. The case was a landmark decision in 2018, underscoring the significance of the arm’s length principle in determining taxable income for multinational corporations.
GlaxoSmithKline v. CIR (Philippines) Read Post »
No trade, no deduction: Tax Court issues Section 11(a) judgment Cliffe Dekker Hofmeyr South Africa December 15 2017 On April
S.Africa: No trade, no deduction: Tax Court issues Section 11(a) judgment Read Post »
Africa tax in Brief by Celia Becker Africa regulatory and business intelligence | executive cbecker@ENSafrica.com cell: +27 82 886 8744 African
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Relocating from South Africa? Key steps to undertake in the emigration process ENSafrica South Africa November 22 2017 There are a number
South Africa: Relocating and emigrating from South Africa Read Post »
Davis Tax Committee report by Hogan Lovells South Africa November 21 2017 The Davis Tax Committee (the Committee) released a further report
I wrote a book on tax risk management that includes tax and strategy. It is called TAX INTELLIGENCE and is
The Chevron Australia Holdings Pty Ltd v Commissioner of Taxation [2017] FCAFC 62 case is a landmark judgment by the Federal Court of Australia concerning the application of transfer pricing rules.
Chevron Australia Holdings Pty Ltd v Commissioner of Taxation 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 |