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Arms Length Principle

Brazil vs Petroleo Brasileiro S.A., March 2026, CARF, Case No 16682.721153/2024-88

Brazil’s CARF upheld the cancellation of a transfer-pricing adjustment levied on PETROBRAS in respect of oil-platform charter fees for the 2019 calendar year, finding that the tax authority could not use the initial contract term as a proxy for the investor’s expected return period. The tribunal also upheld the simultaneous imposition of an isolated penalty for unpaid monthly IRPJ and CSLL estimates alongside the annual-adjustment penalty.

Brazil vs Petroleo Brasileiro S.A., March 2026, CARF, Case No 16682.721153/2024-88 Read Post »

Italy vs La Termoplastic F.B.M. s.r.l., May 2026, Supreme Court, Case No 13482/2026

The Italian Supreme Court dismissed La Termoplastic F.B.M. s.r.l.’s appeal against a tax assessment for the 2010 tax year, upholding adjustments to intra-group transfer prices and disallowing deductions for leasing instalments on contracts shorter than the statutory minimum duration. The court confirmed that the transactional net margin method was properly applied and that no retroactive relief was available in respect of the leasing rules.

Italy vs La Termoplastic F.B.M. s.r.l., May 2026, Supreme Court, Case No 13482/2026 Read Post »

Canada vs ExxonMobil Canada Resources Company, March 2026, Tax Court of Canada, Case No 2017-5069(IT)G

ExxonMobil Canada Resources Company appealed the disallowance of a $36,207,810 deduction for Alaskan gas pipeline feasibility study costs and a related Part XIII tax assessment of $1,810,391. The Tax Court of Canada allowed the appeal in full, holding that the costs were deductible as business expenses and that the transfer pricing and Part XIII provisions did not apply.

Canada vs ExxonMobil Canada Resources Company, March 2026, Tax Court of Canada, Case No 2017-5069(IT)G Read Post »

Luxembourg vs “Holding Company AA”, March 2026, Administrative Court, Case No 48905

A Luxembourg holding company challenged transfer-pricing adjustments covering tax years 2012 to 2015, under which the tax authorities attributed intra-group financing income to it on the basis of a credit-risk guarantee letter it had issued. The Administrative Court partially upheld the challenge, finding that only a guarantee-fee adjustment was justified, and referred the matter back to the Director for reassessment.

Luxembourg vs “Holding Company AA”, March 2026, Administrative Court, Case No 48905 Read Post »

Italy vs GE Medical Systems Italia S.p.A. (Nuovo Pignone Holding S.p.A.), March 2026, Supreme Court, Cases No 7169/2026 and 7163/2026

The Italian Supreme Court dismissed the Revenue Agency’s transfer pricing grounds of appeal in two related cases concerning GE Medical Systems Italia S.p.A., covering tax years 2011, 2013, 2014 and 2015. In both cases the Agency had separately annulled by self-remedy the assessments relating to goodwill amortisation deductibility, and the court declared those grounds moot.

Italy vs GE Medical Systems Italia S.p.A. (Nuovo Pignone Holding S.p.A.), March 2026, Supreme Court, Cases No 7169/2026 and 7163/2026 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 »

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 »

Tanzania vs Amadeus Global Travel Distribution Limited, March 2026, Court of Appeal, Civil Appeal No. 227 of 2025

The Court of Appeal of Tanzania dismissed an appeal by Amadeus Global Travel Distribution Limited against a tax assessment for the 2015 year of income, upholding the inclusion of finance costs in the computation of taxable revenue under the Transactional Net Margin Method. The court held that the appellant’s challenges were substantially questions of fact and evidence evaluation over which it lacked jurisdiction under section 25(2) of the Tax Revenue Appeals Act.

Tanzania vs Amadeus Global Travel Distribution Limited, March 2026, Court of Appeal, Civil Appeal No. 227 of 2025 Read Post »

Portugal vs “A Wide Range, LDA”, April 2026, Supremo Tribunal Administrativo, Case No 01721/10.5BEPRT.SA1

The Supremo Tribunal Administrativo admitted an exceptional review appeal brought by a Portuguese company challenging an additional IRC assessment for the year 2004, which arose from a transfer pricing correction made by the tax authorities. The court held that the questions raised concerning the transfer pricing regime were of fundamental legal and social importance and that its intervention was necessary for a better application of the law.

Portugal vs “A Wide Range, LDA”, April 2026, Supremo Tribunal Administrativo, Case No 01721/10.5BEPRT.SA1 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 »

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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