Mutual Agreement Procedures (MAP) are key mechanisms that ensure fair tax treatment in international transactions. They help resolve conflicts between tax authorities, avoiding double taxation and promoting business growth.
Mutual Agreement Procedures (MAP): Key Guidelines Read Post »
As global trade increases, so does the complexity of transfer pricing arrangements, leading to potential disputes between multinationals and tax authorities. The significance of transfer pricing dispute resolution lies in its ability to prevent double taxation, ensure compliance with global standards, and mitigate the risk of financial penalties.
Effective Transfer Pricing Dispute Resolution Read Post »
The impact of tax residency on South African trusts introduces several complexities that require meticulous planning. This guide explores the critical challenges and tax implications associated with changes in tax residency, underlining the need for strategic foresight when managing trusts across different jurisdictions.
How Changes in Tax Residency Impact South African Trusts Read Post »
The 13th SAIT (South African Institute for Taxation) Transfer Pricing Summit 2024 is set to be a pivotal event for tax professionals and policymakers across the continent. This summit will address critical issues in transfer pricing, an increasingly significant field in South Africa and Africa’s economic landscape.
13th Annual SAIT Transfer Pricing Summit 2024: Key Topics and Insights Read Post »
A Permanent Establishment (PE) refers to a fixed place of business through which a foreign enterprise conducts business in another country. In the context of transfer pricing, a PE plays a crucial role as it determines the taxation rights of a country over the profits of a foreign enterprise.
What is a Permanent Establishment, and How is Its Significance in Transfer Pricing? Read Post »
In August 2024, the Italian Supreme Court delivered a pivotal ruling on transfer pricing, specifically addressing the inclusion of loss-making entities in comparability analyses. This ruling could hopefully show a significant shift in how transfer pricing is approached, emphasizing a more comprehensive and accurate reflection of market realities.
The Italian Supreme Court’s Landmark Ruling on Loss-Making Entities: My Take Read Post »
The Italian Supreme Court’s 2024 ruling mandates including loss-making entities in transfer pricing comparability analysis, aligning with OECD guidelines.
In the increasingly complex landscape of international taxation, Transfer Pricing and Profit Attribution to Permanent Establishments (PEs) have emerged as critical issues. The intricacies involved in appropriately allocating profits to PEs, especially in cross-border scenarios, continue to challenge multinational corporations and tax authorities alike.
Dr. Daniel N Erasmus, a leading expert in international tax law and transfer pricing, will be a key speaker at the upcoming Online Transfer Pricing Conference Africa 2024.
The Academy of Tax Law is excited to announce an online Transfer Pricing Conference specifically emphasising Africa. This event will take place in November 2024 and will delve into global transfer pricing issues.
Announcement: Online Transfer Pricing Conference Focused on Africa Read Post »
The judgment in the case C-623/22, issued by the Court of Justice of the European Union (CJEU) on July 29, 2024, primarily addressed the validity of certain provisions of Directive 2011/16/EU as amended by Directive 2018/822, concerning the mandatory automatic exchange of information on reportable cross-border tax arrangements.
The Assessment Review Committee (ARC) ruled in favor of the Mauritius Revenue Authority (MRA) in the case of Avago Technologies Trading Ltd (ATTL) v/s Director General of the MRA.
Avago Technologies Trading Ltd v/s Director General, MRA Judgment 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 |