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Arms Length Principle

Swedish Court Rejects Tax Challenge to Electricity Contract Damages

The Swedish Supreme Administrative Court set aside lower-court decisions that had applied the transfer-pricing correction rule to deny Kubikenborg Aluminium AB a deduction for damages paid to Vattenfall following early termination of an electricity agreement. The court held that the conditions for applying the correction rule were not satisfied because no income had been transferred from Kubal to its parent, Rusal, within the meaning of the rule.

Swedish Court Rejects Tax Challenge to Electricity Contract Damages Read Post »

Sweden vs Kubikenborg Aluminium AB, May 2026, Supreme Administrative Court, Case No 1334-25

The Swedish Supreme Administrative Court set aside lower-court decisions that had applied the transfer-pricing correction rule to deny Kubikenborg Aluminium AB a deduction for damages paid to Vattenfall following early termination of an electricity agreement. The court held that the conditions for applying the correction rule were not satisfied because no income had been transferred from Kubal to its parent, Rusal, within the meaning of the rule.

Sweden vs Kubikenborg Aluminium AB, May 2026, Supreme Administrative Court, Case No 1334-25 Read Post »

French Court Backs Cost-Plus Pricing for LNG Coordination Services

The French Conseil d’État rejected the Minister’s cassation appeal against the Paris Administrative Court of Appeal’s decision granting partial relief to Engie (formerly GDF Suez) in a transfer pricing dispute concerning intra-group services rendered in connection with a pooled LNG trading and logistics arrangement for the years 2011 to 2014. The Conseil d’État confirmed that the administration had not established an unjustified price gap constituting an indirect transfer of profits to the company’s subsidiaries.

French Court Backs Cost-Plus Pricing for LNG Coordination Services Read Post »

France vs Engie SA, May 2026, Conseil d’État, Case No 496874 (ECLI:FR:CECHR:2026:496874.20260507)

The French Conseil d’État rejected the Minister’s cassation appeal against the Paris Administrative Court of Appeal’s decision granting partial relief to Engie (formerly GDF Suez) in a transfer pricing dispute concerning intra-group services rendered in connection with a pooled LNG trading and logistics arrangement for the years 2011 to 2014. The Conseil d’État confirmed that the administration had not established an unjustified price gap constituting an indirect transfer of profits to the company’s subsidiaries.

France vs Engie SA, May 2026, Conseil d’État, Case No 496874 (ECLI:FR:CECHR:2026:496874.20260507) Read Post »

Czech Republic vs RR Donnelley Transfer Pricing Case

The case Czech Republic vs. RR Donnelley Czech s.r.o. revolved around a transfer pricing dispute concerning the application of Section 23(7) of the Czech Income Tax Act (ITA). The core issue was whether RR Donnelley Czech s.r.o. had correctly applied the arm’s length principle in a transaction involving the purchase of hard disk drives (HDDs) on behalf of Banta Ireland, a related entity.

Czech Republic vs RR Donnelley Transfer Pricing Case Read Post »

Fiat Chrysler Finance Europe and Ireland v Luxembourg: State Aid, Transfer Pricing, and the Arm’s Length Principle

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.

Fiat Chrysler Finance Europe and Ireland v Luxembourg: State Aid, Transfer Pricing, and the Arm’s Length Principle 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