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Transfer Pricing

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 »

Italy vs NN Europe S.p.A., May 2026, Supreme Court, Case No 13136/2026

The Italian Supreme Court dismissed the tax authority’s appeal and held that transfer pricing rules do not apply to an intra-group guarantee provided without remuneration where valid commercial reasons for the transaction are established. The court confirmed that the taxpayer had discharged its burden of proving such reasons, including the risk to the Italian subsidiary’s survival had the parent company entered insolvency.

Italy vs NN Europe S.p.A., May 2026, Supreme Court, Case No 13136/2026 Read Post »

India vs American Express (India) Pvt. Ltd., May 2026, High Court of Delhi, Case No ITA 656/2019

The Delhi High Court decided a Revenue appeal concerning transfer pricing adjustments for Assessment Year 2009-10 in the case of a captive IT-enabled services provider. The court admitted two of seven proposed substantial questions of law and answered both in favour of the Revenue, directing the Transfer Pricing Officer to examine the functional comparability of Cepha Imaging Pvt. Ltd. and to exclude CG Vak Software and Exports Ltd. on account of an extreme turnover disparity.

India vs American Express (India) Pvt. Ltd., May 2026, High Court of Delhi, Case No ITA 656/2019 Read Post »

Italy vs Illva Saronno SpA, May 2026, Supreme Court, Case No 15698/2026

The Italian Supreme Court partly upheld a transfer pricing appeal by Illva Saronno SpA and Illva Saronno Holding SpA, quashing the regional tax court’s ruling on the choice of transfer pricing method and remitting the case for fresh examination. The court rejected the taxpayers’ grounds on procedural fairness, burden of proof and omitted historical facts.

Italy vs Illva Saronno SpA, May 2026, Supreme Court, Case No 15698/2026 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 »

India vs Inductotherm (India) Pvt. Ltd., May 2026, Income Tax Appellate Tribunal, Case No ITA No. 1609/Ahd/2024

The Income Tax Appellate Tribunal, Ahmedabad allowed the appeal of Inductotherm (India) Pvt. Ltd. for statistical purposes, directing deletion of a transfer pricing adjustment of Rs.3,88,46,904 and remanding two further issues to the Assessing Officer for fresh adjudication. The Tribunal held that TNMM at entity level was the most appropriate transfer pricing method, consistent with coordinate bench decisions in the assessee’s own case for earlier assessment years.

India vs Inductotherm (India) Pvt. Ltd., May 2026, Income Tax Appellate Tribunal, Case No ITA No. 1609/Ahd/2024 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 »

Canada vs Owens Corning Canada Holdings ULC, March 2026, Tax Court, Case No. 2026 TCC 60

The Tax Court of Canada quashed appeals by Owens Corning Canada Holdings ULC after holding it lacked jurisdiction to order a downward transfer pricing adjustment sought in the calculation of foreign accrual property income. The court found that such adjustments require the Minister’s discretionary approval under subsection 247(10) of the Income Tax Act and cannot be ordered by this Court.

Canada vs Owens Corning Canada Holdings ULC, March 2026, Tax Court, Case No. 2026 TCC 60 Read Post »

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 »

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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