The Federal Court of Australia’s judgment in PepsiCo, Inc v Commissioner of Taxation provides critical insights into the characterization of payments under intercompany agreements and the application of tax laws.
PepsiCo v Australia: Implications for Royalty Withholding Tax and Diverted Profits Tax Read Post »
The Keysight Technologies Malaysia case underscores the complexities of transfer pricing and tax compliance. By understanding the court’s findings and implementing robust tax risk management strategies, companies can better navigate similar disputes and ensure compliance with tax regulations.
Keysight Technologies v. Malaysia: Implications for Transfer Pricing and Tax Compliance Read Post »
Summary of Malaysian transfer pricing case of Watsons Personal Care Stores vs tax authorities, its implications for multinationals, and key takeaways.
Malaysia Transfer Pricing Case: Watsons Personal Care Stores vs Tax Authorities Read Post »
Summary of the Danish Supreme Court’s landmark ruling on transfer pricing in the Maersk Oil case, with implications for multinationals and tax authorities worldwide.
Danish Supreme Court Upholds Transfer Pricing Adjustment in Maersk Oil Case Read Post »
Luxembourg court rules interest-free loan qualifies as debt, allowing notional interest deduction in landmark transfer pricing case with implications for multinationals.
Explore the critical role of the burden of proof in transfer pricing through analysis of recent Dutch, Czech, and Italian court cases.
Understanding the Burden of Proof in Transfer Pricing: Insights from Recent Court Cases Read Post »
Analysis of Dutch court ruling on arm’s length principle in intra-group financing. Key insights for multinationals on transfer pricing and tax risk management.
Analysis of the ERT Automotive Bohemia case emphasizses the critical role of the burden of proof in transfer pricing disputes and its implications for multinationals.
Czech Transfer Pricing Case Highlights Importance of Burden of Proof Read Post »
Analysis of the Czech transfer pricing case where ERT Automotive Bohemia won against tax authorities, highlighting key issues and implications for multinationals.
Czech Transfer Pricing Case: ERT Automotive Bohemia Wins Appeal Against Tax Authorities Read Post »
Analyze the Italy vs DG transfer pricing case, comparing CUP and TNMM methods from tax authority and taxpayer perspectives. Insights from Prof. Dr. Erasmus.
CUP vs TNMM in Italy vs DG: A Transfer Pricing Method Analysis Read Post »
The Italy vs DG transfer pricing case is a significant ruling that has far-reaching implications for multinational enterprises and tax authorities worldwide. This in-depth analysis examines the key aspects of the judgment, its impact on transfer pricing practices, and the importance of proactive tax risk management.
Transfer Pricing Case Analysis: Italy vs Dolce & Gabbana Read Post »
Detailed analysis of the Federal Court of Australia’s judgment in Mylan Australia Holding Pty Ltd v Commissioner of Taxation [2024] FCA 253, focusing on key points, court findings, and implications for multinationals.
Case Analysis: Mylan Australia Holding Pty Ltd v Commissioner of Taxation 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 |