This case examines the taxation of the domestic permanent establishment of a Hungarian corporation operating in Germany. The central issue revolves around the adjustment of profits under Section 1(5) of the Foreign Tax Act (AStG), specifically how the relationship between the Hungarian corporation and its German branch was treated for tax purposes.
ST Dupont, a French luxury manufacturer, contested additional tax assessments and penalties imposed by the French tax authorities for the financial years 2009 to 2011. The authorities argued that ST Dupont had transferred profits to its subsidiary in Hong Kong by selling products at lower-than-arm’s-length prices.
ST Dupont vs. France Transfer Pricing Judgment Read Post »
This case involves a dispute over the deductibility of financial costs related to loans taken out by the taxpayer (A…, Sociedade Unipessoal, LDA) to finance the acquisition of a 70% shareholding in a related company (C…). The Portuguese Tax Authority (AT) disallowed the deduction, arguing that these financial costs were not indispensable for generating taxable income.
Sociedade Unipessoal, LDA vs Portugal Read Post »
The FG Düsseldorf judgment of May 12, 2023, revolves around the transfer pricing dispute of a multinational enterprise operating a pipeline network across Germany, Belgium, and the Netherlands. The court found that the defendant’s method of profit allocation did not align with the arm’s length principle and violated the existing double taxation treaties.
Germany vs “Z Pipeline”: Transfer Pricing Disputes in Multinational Operations Read Post »
The case revolves around the transfer pricing methods used by Dart Sudamericana S.A. for the importation of EPS pellets from related companies. The primary contention was whether the Comparable Uncontrolled Price (CUP) method or the Net Transaction Margin Method (NTMM) was appropriate for determining the arm’s length price of these transactions.
Dart Sudamericana Transfer Pricing Case Read Post »
The Wisconsin Tax Appeals Commission ruled in favour of the Wisconsin Department of Revenue, affirming its disallowance of royalty deductions claimed by Skechers USA Inc. in relation to intercompany transactions between Skechers and its subsidiary, Skechers USA Inc. II
Skechers USA Inc. vs. USA Read Post »
The dispute focused on the income tax treatment of intellectual property (IP) transactions between 3M’s U.S. subsidiaries and its Brazilian subsidiary, 3M do Brasil Ltda (3M Brazil), for the tax year 2006.
The case revolved around whether Nokia Solutions and Networks Oy had a Permanent Establishment (PE) in India, and whether profits could be attributed to that PE under the India-Finland Double Taxation Avoidance Agreement (DTAA).
Nokia vs. India: Permanent Establishment and Profit Attribution Dispute Read Post »
The case involves two appeals by Fiat Chrysler Finance Europe (formerly Fiat Finance and Trade Ltd) and Ireland, challenging the General Court’s decision to uphold a European Commission ruling that a tax ruling granted by Luxembourg to Fiat Chrysler Finance Europe constituted unlawful state aid.
Eaton Corporation, a global manufacturer of electrical and industrial products, faced significant tax disputes with the IRS regarding its transfer pricing practices. The disputes centered around the company’s Advance Pricing Agreements (APAs) with the IRS, which were intended to establish transfer pricing methodologies for transactions between Eaton and its subsidiaries. The APAs were canceled by the IRS, leading to a tax court case in 2017 and an appeal in 2022.
Eaton Corporation vs. IRS: Transfer Pricing Dispute Read Post »
The case of Medtronic, Inc. vs. Commissioner of Internal Revenue revolves around the complex issue of transfer pricing, particularly concerning the appropriate method to determine the arm’s length royalty rates for the use of intellectual property between Medtronic US and its Puerto Rican subsidiary, MPROC.
Medtronic vs Commissioner of Inland Revenue Read Post »
The Ferragamo France transfer pricing case offers valuable insights for luxury goods companies. This landmark ruling highlights the complexities of transfer pricing in the high-end retail sector.
Ferragamo France Transfer Pricing Case: Key Lessons for Luxury Brands 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 |