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Exactera’s 2024 TP Symposium

I am pleased to announce that I will speak at Exactera’s 2024 TP Symposium in Lausanne, Switzerland. My presentation will focus on the critical area of transfer pricing case law, which has increasingly become a cornerstone of international tax compliance and litigation.

The 2024 Annual TP Symposium will be held from September 17 to 18 in Lausanne, Switzerland. This event focuses on transfer pricing (TP) and intellectual property (IP) policy discussions, featuring keynote speeches, workshops, panels, and case studies led by industry experts. Highlights include insights on managing TP documentation, navigating the digital economy’s impact on TP and IP, and strategies for IP valuation. The symposium also offers networking opportunities and practical sessions tailored to current TP challenges.

ABD vs SARS – A Landmark Case in Africa

During the symposium, I will delve specifically into the landmark ABD vs SARS case, South Africa’s first transfer pricing case. This case has set a significant precedent for both taxpayers and tax authorities and highlights the complexities and nuances that arise in transfer pricing disputes, particularly in emerging markets.

Why Transfer Pricing Case Law Matters

Transfer pricing disputes are becoming more frequent and complex as tax authorities tighten regulations and enforcement. Case law in this area provides crucial guidance on how courts interpret transfer pricing rules and the arm’s length principle. Understanding these judicial decisions is essential for anyone managing transfer pricing risk.

The ABD vs. SARS case, which I’ll analyze in detail, offers invaluable insights. It underscores the importance of robust transfer pricing documentation and the need for companies to carefully justify their pricing strategies in cross-border transactions. The judgment from this case has far-reaching implications, not only for South African entities but also for multinational corporations operating in similar jurisdictions.

What to Expect from My Presentation

In my talk, I will:

  • Examine the facts of the ABD vs SARS case: I will outline the background, the arguments presented by both sides, and the court’s final decision.
  • Discuss the implications of the case: How does this case influence current transfer pricing practices in South Africa and globally?
  • Provide practical guidance On how companies can use this case as a reference to improve their own transfer pricing documentation and compliance efforts.

This session offers practical insights that you can apply directly to your business operations, ensuring that you are better prepared to handle transfer pricing challenges in the evolving global tax environment.

Click here for more information on this judgment >>>

Why You Should Attend

The 2024 TP Symposium is an unparalleled opportunity to stay ahead of the curve in transfer pricing. With a focus on the latest trends, regulatory updates, and case law, this event is a must-attend for tax professionals, legal experts, and business leaders.

For more information and to register for the symposium, please visit the 2024 TP Symposium website.

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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