The case revolved around whether Nokia Solutions and Networks Oy had a Permanent Establishment (PE) in India, and whether profits could be attributed to that PE under the India-Finland Double Taxation Avoidance Agreement (DTAA).
Nokia vs. India: Permanent Establishment and Profit Attribution Dispute Read Post »
The case of UPS Asia Group Pte. Ltd. vs. Asstt. Commissioner of Income Tax revolves around the interpretation of whether the applicant had a “Business Connection” in India and a “Permanent Establishment” (P.E.) under the India-Singapore Double Taxation Avoidance Agreement (DTAA). The Income Tax Appellate Tribunal (ITAT) ruled in favour of UPS Asia Group, stating that when the Indian Associated Enterprise (A.E.) is remunerated at arm’s length price, no further profit attribution is required, making the existence of a P.E. tax-neutral.
Article by: Eyal Bar-Zvi (Herzog Fox & Neeman) Overview Israel’s transfer pricing regime is regulated under Section 85A (Section 85A)
Transfer pricing in a nutshell: Israel Read Post »
Paper by: Norsiah Ahmad, Juahir Mohd-Nor and Norman Mohd-Saleh Fraudulent financial reporting has become an important issue in accounting profession.
Fraudulent Financial Reporting and Companies’ Characteristics: Evidence from Tax Audit Read Post »
Article by Henriette Fuchs (Pearl Cohen Zedek Latzer Baratz) Unlike the taxing authorities in many other countries, the tax authorities
Article by: Reggie Mezu, Bastiaan Moossdorff and Laya Aoun-Hani (Baker McKenzie) The UAE Federal Tax Authority (FTA) has published Public
Federal Tax Authority issues public clarification on transfer of business in the UAE Read Post »
Article by: Dr. Dennis Ndonga (Lecturer, Murdoch University Australia) The rapid growth of cross-border e-commerce has challenged the existing international
International Taxation of E-commerce Business Income Read Post »
Paper by: Reuven S. Avi-Yonah The existing network of over 2,500 bilateral double tax treaties (DTTs) represents an important part
Double Tax Treaties: An Introduction Read Post »
The case of Anwar & Co. v. CIT is a landmark ruling by the Supreme Court of India that delves deep into Permanent Establishment (PE) and its implications for cross-border taxation. The court was tasked with determining whether the activities of a foreign company in India, facilitated through Anwar & Co., constituted a PE, thereby attracting Indian tax liabilities.
Anwar & Co. v. CIT: Understanding Permanent Establishment in International Taxation Read Post »
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 »
The Delhi High Court’s ruling in the Maruti Suzuki India Ltd. v. ACIT case is a landmark decision that addresses the complex issue of whether Advertisement, Marketing, and Promotion (AMP) expenses incurred by Maruti Suzuki India Ltd. (MSIL) constituted an international transaction under Indian Transfer Pricing (TP) laws.
Maruti Suzuki India Ltd. v. ACIT 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 »
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 |