Since the 2012 Union Budget specified that shares of a foreign company would be deemed to be situated in India […]
INDIA: Taxability of overseas share sale – India influences African Tax Administrations Read Post »
COMMENT Tax arbitration via new double tax treaties is on the increase. Hence, knowledge of international arbitration is important. Take
AFRICA: Sub-Saharan Africa and international arbitration – how does that work? Read Post »
Please visit this course website for more information: http://www.iitf.net/academics/career-programs/transfer_pricing_africa/
Advanced Diploma in Transfer Pricing (Africa) Read Post »
Please visit the Seminar website for further information: http://knowledgewithinreach.webs.com/daniel
New Tax Court Rules : Update on the new Objection, Appeal & Tax Court rules Read Post »
Another article about this case is available here – http://taxriskmanagement.com/sca-judgment-on-sars-conduct/ In the case of CSARS v Pretoria East Motors Pty Ltd,
S.AFRICA – The first foray by the Supreme Court of Appeal into SARS’ audit duties Read Post »
MM Zambia Limited v. Zambia Revenue Authority (2014/HP/0100) in the High Court for Zambia, Holden at Lusaka, before the Honourable
MM Zambia Limited v. Zambia Revenue Authority Read Post »
Please download the forum brochure here: Transfer Pricing West Africa Forum
Transfer Pricing West Africa Forum Read Post »
he GlaxoSmithKline transfer pricing case was a landmark decision in Canadian tax law. It involved GSK’s Canadian subsidiary and the Canada Revenue Agency (CRA). The dispute centered on the pricing of ranitidine, the active ingredient in the anti-ulcer drug Zantac.
GlaxoSmithKline vs Canada: Transfer Pricing Case Read Post »
The Xilinx Inc. case revolves around whether costs related to employee stock options (ESOs) should be included in the cost-sharing agreement (CSA) between Xilinx Inc. and its subsidiary Xilinx Ireland (XI) under U.S. tax regulations.
Xilinx Inc. v. Commissioner of Internal Revenue Read Post »
The case of Morgan Stanley & Co. Inc. v. DIT (India) centered on the determination of whether Morgan Stanley & Co. Inc. (MSCo), a U.S.-based company, had a Permanent Establishment (PE) in India through its subsidiary, Morgan Stanley Advantage Services Pvt. Ltd. (MSAS).
Supreme Court Judgment Analysis: Morgan Stanley & Co. Inc. v. DIT (India) Read Post »
The Cadbury Schweppes case is a seminal ruling in the context of the European Union’s freedom of establishment and the limitations on Member States’ tax authorities to impose tax measures on Controlled Foreign Companies (CFCs).
Cadbury Schweppes vs UK: EU Ruling on Freedom of Establishment and Tax Avoidance 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 |