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France vs Engie SA, May 2026, Conseil d’État, Case No 496874 (ECLI:FR:CECHR:2026:496874.20260507)

The French Conseil d’État rejected the Minister’s cassation appeal against the Paris Administrative Court of Appeal’s decision granting partial relief to Engie (formerly GDF Suez) in a transfer pricing dispute concerning intra-group services rendered in connection with a pooled LNG trading and logistics arrangement for the years 2011 to 2014. The Conseil d’État confirmed that the administration had not established an unjustified price gap constituting an indirect transfer of profits to the company’s subsidiaries.

France vs Engie SA, May 2026, Conseil d’État, Case No 496874 (ECLI:FR:CECHR:2026:496874.20260507) Read Post »

Czech Republic vs RR Donnelley Transfer Pricing Case

The case Czech Republic vs. RR Donnelley Czech s.r.o. revolved around a transfer pricing dispute concerning the application of Section 23(7) of the Czech Income Tax Act (ITA). The core issue was whether RR Donnelley Czech s.r.o. had correctly applied the arm’s length principle in a transaction involving the purchase of hard disk drives (HDDs) on behalf of Banta Ireland, a related entity.

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France vs SAS Roger Vivier: TRANSFER PRICING CASE

The judgment revolves around a tax dispute between SAS Roger Vivier Paris, a distributor of luxury goods, and the French tax authorities. The core issue concerns transfer pricing adjustments made for the financial years 2012–2014, with the tax authorities asserting that SAS Roger Vivier Paris indirectly transferred profits to foreign-related parties in non-arm’s length conditions.

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WORKSHOP: Safeguarding Tax Strategies – Setting up an Attorney-Client Privileged Tax Steering Committee

Join Dr. Daniel N Erasmus and Renier van Rensburg for an online workshop on 12 February 2025, discussing the critical role of a Tax Steering Committee in Tax Risk Management. Learn how lawyer-client confidentiality enhances tax strategies for multinational enterprises. Register now!

WORKSHOP: Safeguarding Tax Strategies – Setting up an Attorney-Client Privileged Tax Steering Committee Read Post »

France vs Foncière Vélizy Rose: TRANSFER PRICING CASE

The Council of State reviewed an appeal by Foncière Vélizy Rose (FVR) regarding the withholding tax on an interim dividend of EUR 3.6 million distributed to Vélizy Rose Investment (VRI), a Luxembourg-based entity, which was subsequently paid to Dewnos Investment. The Paris Administrative Court of Appeal had dismissed FVR’s claim to discharge this withholding tax, prompting the appeal.

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UK vs Glencore Energy: Transfer Pricing Case

This case examines the boundaries of judicial review in tax disputes involving the Diverted Profits Tax (DPT), a tax introduced by the Finance Act 2015 to prevent profit shifting by multinationals. Glencore Energy UK Limited (GENUK), a subsidiary of the Swiss-based Glencore International AG (GIAG), was assessed under the DPT framework after HMRC deemed the service fees paid by GENUK to GIAG under a Risk and Services Agreement (RSA) to be excessive.

UK vs Glencore Energy: Transfer Pricing Case Read Post »

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Compare Programmes

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.

Awards Ladder

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

IFF Certificate Courses

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