CASE SUMMARY:
In the landmark case of The Thistle Trust v Commissioner for the South African Revenue Service, the Constitutional Court of South Africa was tasked with examining the application of the conduit principle in the taxation of trusts, particularly focusing on how capital gains are treated within a multi-tiered trust structure.
The Thistle Trust vs C. South African Revenue Service: CASE SUMMARY Read Post »
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The Thistle Trust vs C. South African Revenue Service: JUDGMENT Read Post »
DOWNLOAD the full judgment: RSA vs Wiese & Others
RSA vs Wiese & Others: JUDGMENT Read Post »
CASE SUMMARY:
The Supreme Court of Appeal of South Africa (SCA) ruled against Christoffel Hendrik Wiese and other appellants in their appeal concerning SARS’s efforts to recover a tax debt under section 183 of the Tax Administration Act (TAA).
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CASE SUMMARY:
In Boerdery v SARS, the South African Tax Court addressed the tax treatment of substantial insurance premiums paid by Taxpayer Boerdery to Company XYZ Insurance Company. Boerdery, a farming enterprise, claimed tax deductions on the premiums, contending they qualified as legitimate insurance expenses under section 11(a) of the Income Tax Act, which allows for deductions of expenses that are “actually incurred in the production of income.”
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CASE SUMMARY:
In the matter of F Taxpayer v SARS, the Tax Court of South Africa was tasked with evaluating the procedural compliance and statutory adherence of the South African Revenue Service (SARS) in the taxpayer’s appeal concerning assessments for the 2016 to 2018 tax years. This case brought into focus SARS’s failure to meet prescribed deadlines and its subsequent application for condonation to excuse these delays.
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DOWNLOAD the full judgment: Canada vs Thompson
Canada vs Thompson: JUDGMENT Read Post »
CASE SUMMARY:
In Canada (National Revenue) v. Thompson, the Supreme Court of Canada evaluated the boundary between solicitor-client privilege and the statutory obligations imposed on lawyers under the Income Tax Act (ITA).
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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 |