The Italian Supreme Court’s 2024 ruling mandates including loss-making entities in transfer pricing comparability analysis, aligning with OECD guidelines.
In the increasingly complex landscape of international taxation, Transfer Pricing and Profit Attribution to Permanent Establishments (PEs) have emerged as critical issues. The intricacies involved in appropriately allocating profits to PEs, especially in cross-border scenarios, continue to challenge multinational corporations and tax authorities alike.
The Academy of Tax Law is excited to announce an online Transfer Pricing Conference specifically emphasising Africa. This event will
Announcement: Online Transfer Pricing Conference Focused on Africa Read Post »
Dr. Daniel N Erasmus, a leading expert in international tax law and transfer pricing, will be a key speaker at the upcoming Online Transfer Pricing Conference Africa 2024.
The Academy of Tax Law is excited to announce an online Transfer Pricing Conference specifically emphasising Africa. This event will take place in November 2024 and will delve into global transfer pricing issues.
Announcement: Online Transfer Pricing Conference Focused on Africa Read Post »
The judgment in the case C-623/22, issued by the Court of Justice of the European Union (CJEU) on July 29, 2024, primarily addressed the validity of certain provisions of Directive 2011/16/EU as amended by Directive 2018/822, concerning the mandatory automatic exchange of information on reportable cross-border tax arrangements.
The Transfer Pricing Compliance Assurance – An End-to-End Toolkit developed by the United Nations Subcommittee on Transfer Pricing is a comprehensive guide designed to support tax administrations, particularly in developing countries, in ensuring efficient and effective transfer pricing compliance.
Optimised Transfer Pricing Compliance: UNs End-to-End Toolkit Read Post »
The Assessment Review Committee (ARC) ruled in favor of the Mauritius Revenue Authority (MRA) in the case of Avago Technologies Trading Ltd (ATTL) v/s Director General of the MRA.
Avago Technologies Trading Ltd v/s Director General, MRA Judgment Read Post »
The importance of organizational structure and business overview in transfer pricing documentation cannot be overstated. These elements provide the foundation for accurate and defensible transfer pricing practices.
Transfer pricing policies and methodologies are critical components of transfer pricing documentation, which is essential for multinational corporations (MNCs) to ensure tax compliance and avoid profit shifting.
Transfer Pricing Policies and Methodologies in Transfer Pricing Documentation Read Post »
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 »
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 |