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Disallowed Deduction

Tanzania vs Total Tanzania Limited, April 2026, Court of Appeal, Case No Civil Appeal No 425 of 2023

The Court of Appeal of Tanzania quashed the decisions of the Tax Revenue Appeals Board and the Tax Revenue Appeals Tribunal in a dispute over the deductibility of group technical assistance fees paid by Total Tanzania Limited to Total Outre Mer. The court held that the Board’s judgment was fatally defective because the Vice Chairman had failed to record reasons for disagreeing with a dissenting member’s opinion, as required by rule 15(3) of the Tax Revenue Appeals Board Rules, 2018.

Tanzania vs Total Tanzania Limited, April 2026, Court of Appeal, Case No Civil Appeal No 425 of 2023 Read Post »

Norway vs Orlen Upstream Norway AS (formerly PGNiG Upstream Norway AS), March 2026, Supreme Court, Case No HR-2026-707-A

Norway’s Supreme Court upheld the Court of Appeal’s ruling that discretionary income assessment under section 13-1 of the Tax Act in thin capitalisation cases must be based on a net assessment of the entire transaction, allowing interest margins on intra-group loans within borrowing capacity to be adjusted upwards in the taxpayer’s favour. The State’s appeal was dismissed and it was ordered to pay costs of NOK 2,000,000 to Orlen Upstream Norway AS.

Norway vs Orlen Upstream Norway AS (formerly PGNiG Upstream Norway AS), March 2026, Supreme Court, Case No HR-2026-707-A Read Post »

Netherlands vs “X Hybrid B.V.”, May 2026, Supreme Court, Case No 21/04746 (ECLI:NL:HR:2026:736)

The Dutch Supreme Court upheld the denial of interest deductions on loans used to finance a hybrid cross-border joint-venture structure, finding that neither the compensating-levy safe harbour nor EU law prevented application of the counter-counter-evidence rule under Article 10a of the Wet Vpb 1969 and the doctrine of fraus legis. All four grounds of the principal cassation appeal were dismissed.

Netherlands vs “X Hybrid B.V.”, May 2026, Supreme Court, Case No 21/04746 (ECLI:NL:HR:2026:736) Read Post »

Italy vs KAI S.r.l. (Shell Italia Aviazione), March 2026, Supreme Court, Case No 5753/2026

The Italian Supreme Court quashed the Regional Tax Commission’s ruling that intragroup service costs charged to KAI S.r.l. (formerly Shell Italia Aviazione) were fully deductible, holding that the lower court had applied insufficiently rigorous standards of proof of effective utility. The court also rejected the taxpayer’s cross-appeal seeking cross-period compensation for costs deducted in the wrong tax year.

Italy vs KAI S.r.l. (Shell Italia Aviazione), March 2026, Supreme Court, Case No 5753/2026 Read Post »

Portugal’s Top Court Blocks Free Capital Adjustment on Legal Grounds

The Portuguese Supreme Administrative Court dismissed the tax authority’s appeal and annulled an additional IRC assessment for the 2006 tax year, holding that Article 58 of the CIRC did not authorise the recharacterisation of part of a branch’s intercompany loans as free capital in order to disallow the corresponding interest deduction. No provision of Portuguese domestic law or the Portugal-France double tax convention applicable at the time supported that recharacterisation.

Portugal’s Top Court Blocks Free Capital Adjustment on Legal Grounds Read Post »

Italy vs SATA Sud S.p.A., April 2026, Supreme Court, Case No 10456/2026

The Italian Supreme Court allowed the tax authority’s appeal concerning the deductibility for IRAP purposes of intra-group consultancy costs of euro 211,804.28 charged at a flat rate of 1.75% of monthly sales. The court held that the lower court had misallocated the burden of proof and that a formal contract and absence of qualified staff were insufficient, without proof of the specific services actually performed in the relevant tax period.

Italy vs SATA Sud S.p.A., April 2026, Supreme Court, Case No 10456/2026 Read Post »

India vs Pernod Ricard India Pvt. Ltd., May 2026, Supreme Court, Case No SLP (Civil) Diary No 74598/2025

The Supreme Court of India dismissed the tax authority’s Special Leave Petition challenging a Delhi High Court ruling in favour of Pernod Ricard India Private Limited, on grounds of both delay and lack of merit. The petition was filed 384 days late and the Court found no good ground to interfere with the High Court’s order.

India vs Pernod Ricard India Pvt. Ltd., May 2026, Supreme Court, Case No SLP (Civil) Diary No 74598/2025 Read Post »

Portuguese Supreme Court Rejects Free Capital Transfer Pricing

The Portuguese Supreme Administrative Court dismissed the tax authority’s appeal and annulled an additional IRC assessment for the 2006 tax year, holding that Article 58 of the CIRC did not authorise the recharacterisation of part of a branch’s intercompany loans as free capital in order to disallow the corresponding interest deduction. No provision of Portuguese domestic law or the Portugal-France double tax convention applicable at the time supported that recharacterisation.

Portuguese Supreme Court Rejects Free Capital Transfer Pricing Read Post »

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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