Transfer pricing disputes to threaten big companies’ profit growth Postgraduate Diploma in Transfer Pricing | Starts 29 Oct 2018 Transfer pricing related […]
Transfer pricing disputes to threaten big companies’ profit growth Read Post »
By ENSAfrica Groups of companies often wish to restructure or rationalise their operations. This generally involves a transfer of companies
S.Africa: When does tax avoidance apply Read Post »
https://blog.goodaudience.com/blockchain-explained-in-1000-words-6bb83020b036
Blockchain explained in a 1000 words Read Post »
Zimbabwe slaps ‘catastrophic’ tax on electronic transactions Zimbabwe’s newly appointed Finance and Economic Development Minister Mthuli Ncube has announced a
Zimbabwe slaps ‘catastrophic’ tax on electronic transactions Read Post »
The growth in online media platforms has caught a number of African countries off guard. Some, including Kenya, Tanzania, Uganda,
Africa: Internet taxes Read Post »
Canada: Cameco’s Canada Tax Court Victory Brings Relief for Companies • Court rejects government’s arguments of “sham” transactions • Lawyers divided on
Canada: TP case – Cameco’s Canada Tax Court Victory Brings Relief for Companies Read Post »
The Rising Tide of Tax Disputes 02 October 2018 By JJ van der Walt, Candidate Attorney, and Arnaaz Camay, Tax
Africa: The Rising Tide of Tax Disputes Read Post »
GHANA: High Court rules that payment of minimum disputed amount is a prerequisite for filing an appeal by Renier van
Black Sash Trust (Freedom Under Law Intervening) v Minister of Social Development and Others (Corruption Watch (NPC) RF and South
by Cliffe Dekker Homeyr – Ben Strauss and Jerome Brink South African courts have held, on a number of occasions, that taxpayers are
S.Africa: No tax deduction for damages paid for deliberate breach of supply contract Read Post »
Audits Microsoft, J&J Tax Heads Divulge Tax Feud Strategies Snapshot • Johnson & Johnson uses software tool to keep track of
TP: Audits – Microsoft, J&J Tax Heads Divulge Tax Feud Strategies Read Post »
On 25 July 2018, the South African Revenue Service (SARS) published its Guide on Mutual Agreement Procedures (Guide) as a
S.Africa: Mapping out MAP processes – SARS’ new guidelines 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 |