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 recent approval by the OECD Council of the OECD Model Tax Convention Update 2024 marks a pivotal moment for international tax practitioners and multinational organizations
Article 26 of the OECD Model Tax Convention Update 2024 Read Post »
The recent document on Pillar One’s Amount B offers a critical insight into the evolving landscape of global tax regulations, highlighting its significance for international tax practitioners and academics.
The Importance of Pillar One’s Amount B Read Post »
Join us for a critical online workshop, Quo Vadis VAT in a Digitalised World: The Need for Multilateral Coordination, on Wednesday, 28 February, at 14:00 GMT. This complimentary session, led by expert Robert van Brederode, addresses the evolving challenges VAT faces in our digital economy.
Exclusive Workshop Invite: Navigating VAT in the Digital Economy Read Post »
The “TPA: Transfer Pricing Global Documentation Handbook – December 2023” is a comprehensive guide for multinational companies navigating the complexities of transfer pricing documentation in compliance with global tax regulations. The handbook emphasizes the importance of consistency across essential documents such as Corporate Income Tax returns, Master Files, Local Transfer Pricing Files, Country-by-Country reports, and more, to avoid common pitfalls like inconsistent treatment of intercompany transactions and discrepancies between commercial and tax books.
The TPA Transfer Pricing Global Documentation Handbook Read Post »
Having prepared and argued at numerous Transfer Pricing trials, I thought it a good idea to commit my journey and experiences to paper as a guide to others about to travel this path in a tumultuous world where revenue authorities are looking to maximize their tax collections.
BOOK UPDATE: “CONDUCTING A TP TRIAL” – CHAPTER 1 NOW AVAILABLE 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.
Learn how to best Conduct a Transfer Pricing Trial with leading experts Prof. Dr. Daniel N Erasmus and Mr. Renier van Rensburg from Middlesex University and IITF.
FREE Online Workshop: Conducting a Transfer Pricing Trial Read Post »
This reminds me of a recent issue raised by a client MNE in Africa. The taxpayer was facing a revised tax assessment and had to pay 30% of the revised assessment to advance the matter to tax dispute resolution, i.e. object and then follow the tax dispute resolution process.
TRYING TO SETTLE TAX DISPUTES OUTSIDE THE PARAMETERS OF TAX LEGISLATION 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
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 »
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 |