With transfer pricing audits becoming increasingly aggressive and complex, multinational corporations are facing unprecedented scrutiny and litigation risk from revenue authorities worldwide.
This Postgraduate Certificate programme directly addresses this escalating challenge, empowering tax professionals, legal advisors, and corporate leaders with essential litigation competencies to proactively manage and defend transfer pricing disputes.
Combining rigorous academic insights with Dr. Daniel N Erasmus' extensive global litigation experience, this programme delivers practical strategies, expert witness management techniques, and courtroom advocacy skills aligned with OECD and UN guidelines.
According to EY (2023), TP audits have increased by 79% in intensity and number.
Advance professional credibility by gaining specialised litigation expertise, recognised and validated by Middlesex University
Expand career opportunities with enhanced competencies to manage high-stakes transfer pricing disputes confidently
Strengthen negotiation and advocacy skills, significantly increasing your impact in discussions with tax authorities and judicial bodies
Grow your professional network, connecting with internationally respected tax litigation experts and peers from diverse industries
Increase personal marketability, positioning yourself as a strategic leader in transfer pricing risk management and litigation
100% online – units released fortnightly via the Virtual Learning Environment, with recorded lectures, prescribed reading and live Q&A tutorials
Study at your own pace, when and where convenient – no need to travel or take time off work
Explore a variety of course materials including videos, case studies and written units
TRACK RECORD – we have over 30 years of experience in providing training to the banking, finance and energy sectors
KNOWLEDGE – all of our trainers are highly experienced practitioners and leading subject matter experts
VALUE – we provide a practical training experience with skills that can be used immediately
The aim of this foundational unit is to introduce participants to the core principles and strategic considerations that underpin transfer pricing litigation. As multinational enterprises increasingly engage in complex cross-border transactions, revenue authorities worldwide have intensified their scrutiny, triggering significant litigation risks.
This unit equips participants with the essential knowledge required to understand why transfer pricing disputes arise, how to identify common triggers, and the key challenges encountered during litigation. Participants will explore the Arm’s Length Principle (ALP) in detail, alongside critical insights drawn from the OECD and UN Transfer Pricing Guidelines, setting a robust framework for understanding international best practices.
Drawing extensively on the global litigation experience of Dr Daniel N Erasmus, participants will analyse real-world scenarios to gain practical insights into managing disputes effectively. Through case studies from diverse jurisdictions, participants will appreciate the complexities and intricacies involved in transfer pricing litigation. By establishing a solid theoretical and practical foundation, this unit prepares participants to strategically approach transfer pricing litigation, setting the stage for advanced exploration of litigation strategy, expert evidence, and courtroom advocacy in subsequent units.
Upon successful completion of this unit, participants will be able to:
The aim of this unit is to equip participants with the essential skills and advanced understanding necessary to effectively prepare, critically assess, and robustly defend transfer pricing studies within the context of international tax audits and litigation. Given the heightened scrutiny from revenue authorities worldwide, meticulous preparation and rigorous documentation of transfer pricing studies have become fundamental in managing audit risk and avoiding costly litigation.
Participants will develop a comprehensive understanding of identifying and accurately defining arm’s length transactions, focusing on key variables and comparability factors that underpin credible transfer pricing studies.
Through detailed exploration of OECD and UN Transfer Pricing Guidelines, this unit emphasises the practical application of these internationally accepted frameworks to ensure compliance and reduce vulnerability to audits. Participants will engage with real-world case studies to identify common pitfalls, weaknesses, and limitations inherent in transfer pricing documentation. By drawing insights from successful and unsuccessful examples of transfer pricing studies, participants will learn to proactively mitigate risks and strengthen their documentation strategies, enhancing both corporate compliance and their personal effectiveness as strategic advisors.
Upon successful completion of this unit, participants will be able to:
This unit aims to prepare participants to effectively manage and strategically respond to initial transfer pricing audits conducted by revenue authorities. In the current regulatory environment, initial responses to audits significantly influence the trajectory and outcome of transfer pricing disputes. Participants will gain in-depth knowledge of audit procedures, including understanding the powers of revenue authorities, information exchange protocols, and appropriate initial engagement practices. The unit emphasises the critical importance of assembling skilled audit response teams and developing clear protocols for document collection, collation, and preservation, ensuring preparedness and compliance from the outset.
Leveraging practical insights and examples from Dr Daniel N Erasmus’ extensive experience with global tax audits, participants will explore strategies for handling initial requests, communicating effectively with tax authorities, and mitigating risks associated with early stages of transfer pricing investigations. This unit empowers participants with practical, actionable strategies designed to reduce the risk of audit escalation, enabling them to confidently manage the audit process and position their organisation for a successful resolution or advantageous negotiation.
Upon successful completion of this unit, participants will be able to:
This unit aims to develop participants’ proficiency in understanding, managing, and effectively presenting expert evidence within the rigorous evidentiary standards applicable to transfer pricing litigation. Given the pivotal role expert testimony plays in influencing trial outcomes, mastery of evidentiary principles is critical. Participants will explore core evidentiary concepts, including hearsay, best evidence rules, exceptions, and internationally recognised standards such as the Daubert principle. Through detailed case examples, participants will gain insights into the strategic selection, preparation, and utilisation of expert witnesses, ensuring their testimony withstands courtroom scrutiny and enhances litigation positions.
Drawing on practical experiences from Dr Daniel N Erasmus’ extensive trial history, the unit provides participants with tactical approaches for structuring expert reports, conducting impactful direct examinations, and effectively cross-examining opposing expert witnesses. Participants will critically analyse real-world transfer pricing trials to understand best practices and pitfalls associated with expert testimony. Ultimately, this unit will enable participants to confidently integrate expert evidence into their litigation strategy, significantly increasing their capacity to achieve favourable outcomes in complex transfer pricing disputes.
Upon successful completion of this unit, participants will be able to:
This unit aims to equip participants with advanced skills in trial preparation and strategic litigation planning essential for successfully managing transfer pricing disputes. Recognising that meticulous preparation and coherent litigation strategy significantly influence trial outcomes, this unit delves deeply into building highly effective legal and expert trial teams, formulating targeted litigation strategies, and mastering courtroom advocacy. Participants will explore techniques for conducting comprehensive mock trials and rehearsals, ensuring preparedness for rigorous courtroom dynamics and procedural complexities.
Drawing extensively on Dr Daniel N Erasmus’ substantial courtroom experience, the unit provides practical insights into developing persuasive opening statements, powerful closing arguments, and effectively managing documentary and evidentiary challenges during trial. By critically examining real-world scenarios and exploring best-practice examples, participants will learn to anticipate opposing arguments and dynamically respond to courtroom developments. Upon completion, participants will be strategically positioned to execute well-crafted litigation plans, proactively mitigating litigation risks and maximising prospects for favourable judicial outcomes in transfer pricing disputes.
Upon successful completion of this unit, participants will be able to:
The aim of this unit is to thoroughly prepare participants to effectively manage and conduct all aspects of a transfer pricing trial. Given the complexity, strategic depth, and high stakes inherent in these proceedings, participants will acquire advanced knowledge of courtroom procedures, persuasive advocacy techniques, and the structured management of documentary and testimonial evidence. The unit will guide participants through the critical phases of trial—including opening statements, direct and cross-examinations, and closing arguments—while emphasising strategies tailored specifically to transfer pricing litigation contexts.
Leveraging Dr Daniel N Erasmus’ extensive litigation experience, participants will learn proven techniques for confidently navigating courtroom dynamics, handling unexpected challenges, and persuasively advocating their positions before judicial bodies. The unit incorporates practical workshops and mock trial scenarios to enable participants to apply and refine their skills in realistic settings. Ultimately, participants will leave this unit fully prepared to conduct high-stakes transfer pricing trials effectively, positioning their organisations for successful outcomes and minimising litigation risk.
Upon successful completion of this unit, participants will be able to:
The aim of this unit is to equip participants with advanced strategic insights into effectively managing post-trial actions and navigating the appeals process in transfer pricing litigation. Recognising that litigation does not conclude with the initial judgment, this unit emphasises critical post-trial evaluation, judgment analysis, and the strategic considerations necessary for pursuing appeals or negotiating favourable settlements. Participants will gain a robust understanding of procedural and substantive grounds for appeals, ensuring preparedness for complex appellate proceedings and alternative dispute resolution methods.
Leveraging the extensive experience and practical insights of Dr Daniel N Erasmus, this unit guides participants through structured procedures for post-trial reviews, feedback processes, and strategic negotiations with revenue authorities. By analysing real-world cases, participants will identify best practices and common pitfalls associated with appellate litigation. Upon completion, participants will possess the strategic competencies required to critically assess judgments, proactively manage post-trial negotiations, and execute appeals effectively, ensuring optimal outcomes and safeguarding corporate interests.
Upon successful completion of this unit, participants will be able to:
The aim of this advanced unit is to provide participants with a comprehensive and nuanced understanding of contemporary, high-level issues and strategic considerations in transfer pricing litigation. As tax authorities worldwide employ increasingly sophisticated approaches, participants must remain ahead by critically analysing landmark cases, innovative methodologies, and evolving interpretative trends. This unit explores contentious topics such as bundled transactions, price premium methods, and economic versus legal ownership arguments (DEMPE), alongside an in-depth evaluation of OECD and UN Guidelines versus alternative methodologies in litigation.
Participants will deepen their capability to strategically position their organisation during transfer pricing disputes through careful examination of significant cases— including landmark judgments and emerging trends from diverse jurisdictions.
Drawing directly on Dr Daniel N Erasmus’ extensive practical experience and detailed analysis of recent global litigation cases, participants will acquire strategic insights into handling complex cross-border litigation scenarios. This unit empowers participants to confidently navigate sophisticated litigation scenarios, proactively address evolving transfer pricing challenges, and strategically mitigate risks to deliver sustainable organisational outcomes.
Upon successful completion of this unit, participants will be able to:
Early-bird deadline: Save GBP 229.90 if you book by 29 April 2026
| Early bird | Standard | |
|---|---|---|
| Course Only | GBP 2,299.00 less GBP 229.90 early-booking saving (book by 29 April 2026) | GBP 2,299.00 |
| Course with Postgraduate Certificate (issued by Middlesex University) | GBP 2,706.00 less GBP 229.90 early-booking saving (book by 29 April 2026) | GBP 2,706.00 |
Upgrades: Add the Postgraduate Certificate option (certification issued by Middlesex University) — GBP 2,706.00 total instead of GBP 2,299.00 course-only · Progress to the PG Certificate in Transfer Pricing —
All fees listed are exclusive of VAT, GST, sales tax, or any other applicable taxes; relevant taxes will be added at the point of invoicing. If you have a VAT ID, include it during registration as it may affect the tax rate applied.
Pay securely online via credit card or request an invoice with bank transfer details included.
If you wish to pay in EUR, select the GBP price – an invoice reflecting the EUR equivalent will be sent.
This course is also available as a customised in-house training solution for organisations.
Group discounts are available.
Dr Erasmus's primary role on the academic panel is to ensure every programme is designed and delivered to a professional standard…
This programme is ideal for C-Suite executives, corporate leaders, legal counsel, financial executives, and tax professionals. The study of conducting a transfer pricing trial is vital to a global audience within the remit of business operations, accountancy, finance, audit and economic development. It is relevant to people seeking to ensure their organisation's compliance and success when navigating the challenges and complexities of tax management.
Graduates will be able to identify tax risks and evaluate their impact, develop strategies to manage and mitigate identified risks, understand the principles and practices of transfer pricing, gain insights into effective communication and negotiation with tax authorities, and master the processes involved in resolving tax disputes from initial engagement to litigation and settlement. Businesses benefit through stronger compliance and financial stability; individuals gain career advancement, Middlesex University accreditation, leadership preparation and a global perspective on international tax issues.
The programme emphasises real-world applications through case studies, simulations, and interactive sessions, ensuring learners can apply theoretical knowledge to practical scenarios. It covers the latest developments in tax regulations and compliance, with a unique focus on international tax issues and jurisdiction-specific challenges. This global perspective is complemented by the extensive expertise of course director Prof. Dr. Daniel N. Erasmus. All attendees have the option to earn a Postgraduate Certificate from Middlesex University upon successful completion.
Cost effective – study around your busy schedule with no need to travel. 100% online – units released fortnightly via our Virtual Learning Environment. Real-life application – apply your new knowledge and skills to your work as the course progresses. Content – explore videos, case studies, and written units. Flexibility – access and study when and where convenient. Interaction – meet like-minded participants on the online forum. Assessment – check your understanding with online quizzes.
Register your interest, download the course brochure, or book a 15-minute consult. All attendees have the option to earn a Postgraduate Certificate from Middlesex University upon successful completion.
Prefer to talk? Book a 15-minute consult · Mon–Fri, 08h00–17h00 (GMT+2) · connect@academyoftaxlaw.com
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