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 »
Explore the implications of the new global minimum corporate tax for multinational corporations, including both challenges and opportunities.
SOUTH AFRICA: The Impact of Global Minimum Corporate Tax on Multinationals Read Post »
The case involves the failure of SARS to finalize the value added tax (VAT) audit of Kusasa Refining for the period from January 2019 to February 2021, despite the company providing all the requested information and documents.
I/I/T/F Head of Academic Development, Prof Dr Daniel N. Erasmus was in attendance at the event and delivered a key-note presentation on:
TRANSFER PRICING – THE NOOSE TIGHTENS FURTHER
GTC Conference 2023 Read Post »
Transfer pricing (TP) disputes have always posed challenges to multinational enterprises (MNEs) and tax authorities. The interpretation and implementation of arm’s length principles, the backbone of TP regulations, have led to an increasing number of TP disputes across the globe. This article considers emerging trends, emphasising the critical role of TP expert witnesses in any TP dispute.
Emerging Trends in Transfer Pricing Read Post »
In the ever-evolving landscape of taxation, the ability to navigate tax disputes effectively is more crucial than ever. I am thrilled to introduce our newly launched fully online course, “MASTERING TAX DISPUTE RESOLUTION IN SOUTH AFRICA.”
Unlocking the Complexities of Tax Dispute Resolution in South Africa: Read Post »
I/I/T/F Head of Academic Development, Prof Dr Daniel N. Erasmus was in attendance at the event and delivered a key-note presentation on:
TRANSFER PRICING – THE NOOSE TIGHTENS FURTHER
SOUTH AFRICAN INSTITUTE OF TAXATION (SAIT) Transfer Pricing Summit 2023 Read Post »
There is no excerpt because this is a protected post.
Protected: SAIT TP Summit I/I/T/F Document Download Read Post »
The article was written and published by: ReganVanRooy 10 common mistakes in SA corporate tax returns – Part II CLICK
SOUTH AFRICA: Think Tax compliance is simple? Think again (PART 2) Read Post »
AUTHOR: Ziyaad Moosa – PKF Octagon (Johannesburg) With effect from 16 September 2022, The South African Revenue Services (SARS) discontinued
SOUTH AFRICA: Replacement of IT14SD forms – New SARS Verification Process 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 |