The Transactional Net Margin Method (TNMM) is a pivotal tool in transfer pricing, used to ensure that transactions between associated enterprises are conducted at arm’s length. This method compares the net profit margin of a taxpayer from a controlled transaction with that of comparable uncontrolled transactions.
Understanding the Transactional Net Margin Method (TNMM) in Transfer Pricing Read Post »
The Cost Plus Method is a widely used approach in transfer pricing for determining arm’s length prices between related entities. This method is particularly useful for manufacturers, service providers, and other businesses that add value to goods or services before transferring them to related parties.
The Cost Plus Method in Transfer Pricing Read Post »
The Comparable Uncontrolled Price (CUP) Method is one of the primary transfer pricing methods used to determine arm’s length prices for transactions between related entities.
Understanding the Comparable Uncontrolled Price (CUP) Method in Transfer Pricing Read Post »
Summary of the Danish Supreme Court’s landmark ruling on transfer pricing in the Maersk Oil case, with implications for multinationals and tax authorities worldwide.
Danish Supreme Court Upholds Transfer Pricing Adjustment in Maersk Oil Case Read Post »
The Resale Price Method in Transfer Pricing is a fundamental approach used by multinational enterprises (MNEs) to ensure compliance with international tax regulations.
Understanding the Resale Price Method in Transfer Pricing Read Post »
Luxembourg court rules interest-free loan qualifies as debt, allowing notional interest deduction in landmark transfer pricing case with implications for multinationals.
Learn about the Arm’s Length Principle in Transfer Pricing, its importance, methods, and why consulting experts like TRM is crucial for compliance and risk management.
The Arm’s Length Principle in Transfer Pricing Read Post »
Explore the critical role of the burden of proof in transfer pricing through analysis of recent Dutch, Czech, and Italian court cases.
Understanding the Burden of Proof in Transfer Pricing: Insights from Recent Court Cases Read Post »
Analysis of Dutch court ruling on arm’s length principle in intra-group financing. Key insights for multinationals on transfer pricing and tax risk management.
Discover why thorough economic analysis in transfer pricing is essential for compliance and profit optimization. Learn how experts like TRM can help.
The Importance of Thorough Economic Analysis in Transfer Pricing Read Post »
Analysis of the ERT Automotive Bohemia case emphasizses the critical role of the burden of proof in transfer pricing disputes and its implications for multinationals.
Czech Transfer Pricing Case Highlights Importance of Burden of Proof Read Post »
Analysis of the Czech transfer pricing case where ERT Automotive Bohemia won against tax authorities, highlighting key issues and implications for multinationals.
Czech Transfer Pricing Case: ERT Automotive Bohemia Wins Appeal Against Tax Authorities 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 |