ExxonMobil Canada Resources Company appealed the disallowance of a $36,207,810 deduction for Alaskan gas pipeline feasibility study costs and a related Part XIII tax assessment of $1,810,391. The Tax Court of Canada allowed the appeal in full, holding that the costs were deductible as business expenses and that the transfer pricing and Part XIII provisions did not apply.
The Tax Court of Canada quashed appeals by Owens Corning Canada Holdings ULC after holding it lacked jurisdiction to order a downward transfer pricing adjustment sought in the calculation of foreign accrual property income. The court found that such adjustments require the Minister’s discretionary approval under subsection 247(10) of the Income Tax Act and cannot be ordered by this Court.
Canada vs Owens Corning Canada Holdings ULC, March 2026, Tax Court, Case No. 2026 TCC 60 Read Post »
The case of Canada v. General Electric Capital Canada Inc. (2010 FCA 344) revolved around whether guarantee fees paid by GE Canada to its parent company, GECUS, adhered to the arm’s length principle under Canadian tax law. GE Canada claimed deductions for these fees in its income calculations for the 1996–2000 taxation years.
Canada vs General Electric Capital Canada: Transfer Pricing Case Read Post »
In Canada (National Revenue) v. Thompson, the Supreme Court of Canada evaluated the boundary between solicitor-client privilege and the statutory obligations imposed on lawyers under the Income Tax Act (ITA).
The Dow Chemical Canada case underscores the complex interplay between tax law, administrative discretion, and jurisdictional issues in transfer pricing disputes.
Dow Chemical Canada ULC v. The King: Tax Court Jurisdiction in Transfer Pricing Disputes Read Post »
The Federal Court of Appeal’s ruling in the case between Her Majesty The Queen and Cameco Corporation centers on the application of Canada’s transfer pricing rules, particularly under Section 247 of the Income Tax Act.
Canada (Her Majesty the Queen) v. Cameco Corporation Read Post »
he GlaxoSmithKline transfer pricing case was a landmark decision in Canadian tax law. It involved GSK’s Canadian subsidiary and the Canada Revenue Agency (CRA). The dispute centered on the pricing of ranitidine, the active ingredient in the anti-ulcer drug Zantac.
GlaxoSmithKline vs Canada: Transfer Pricing Case 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 |