atl_logo_white_png_RETINA
atl_logo_white_png_RETINA
Main Menu

Tax Treaty Interpretation

United Kingdom vs Burlington Loan Management DAC, April 2026, Court of Appeal, Case No CA-2024-001809 ([2026] EWCA Civ 461)

The Court of Appeal dismissed HMRC’s appeal against the Upper Tribunal’s decision that approximately £90.8 million of post-administration interest received by an Irish-resident investment company on a purchased debt claim in the Lehman Brothers International (Europe) administration was exempt from UK withholding tax under Article 12(1) of the UK-Ireland double taxation treaty. The court held that neither the seller nor the buyer had a main purpose of ‘taking advantage of’ Article 12(1) within the meaning of the treaty’s anti-abuse provision, Article 12(5).

United Kingdom vs Burlington Loan Management DAC, April 2026, Court of Appeal, Case No CA-2024-001809 ([2026] EWCA Civ 461) Read Post »

France vs Coupole Finance, March 2026, Administrative Court of Appeal of Nantes, Case No 25NT01793

A Luxembourg-registered company, Coupole Finance, was found to have its effective management and a permanent establishment in France and was assessed to corporate income tax and VAT for the years 2003 to 2010, together with an 80% penalty for concealed activity. The Administrative Court of Appeal of Nantes dismissed the company’s appeal against those assessments.

France vs Coupole Finance, March 2026, Administrative Court of Appeal of Nantes, Case No 25NT01793 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 »

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 »

Shopping Cart
Scroll to Top

Compare Programmes

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