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SSRN Research Papers

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1. Tax Planning as Part of a Tax Risk Management ProcessThomas Jefferson School of Law Research Paper No. 1482423
Number of pages: 88 Posted: 04 Oct 2009 Last Revised: 24 May 2010
Daniel N. Erasmus
Thomas Jefferson School of Law
Downloads1,204(15,530)

2. Proactive Tax Risk Management
Thomas Jefferson School of Law Research Paper No. 1435612
Number of pages: 36 Posted: 23 Sep 2009 Last Revised: 20 Jun 2011
Daniel N. Erasmus
Thomas Jefferson School of Law
Downloads689(34,748)

3. Tax Risk Management Under SOX 404 and FIN 48
Thomas Jefferson School of Law Research Paper No. 1480978
Number of pages: 20 Posted: 04 Oct 2009 Last Revised: 16 Dec 2009
Daniel N. Erasmus
Thomas Jefferson School of Law
Downloads625(39,588)

4. Special Report: Global Tax Audit and Controversy Risk Management
Thomas Jefferson School of Law Research Paper No. 1575723
Number of pages: 26 Posted: 26 Mar 2010 Last Revised: 21 Jun 2011
Daniel N. Erasmus
Thomas Jefferson School of Law
Downloads488(54,367)

5. Taxpayer’s Constitutional Rights: A South African Perspective
Thomas Jefferson School of Law Research Paper No. 1478784
Number of pages: 52 Posted: 27 Sep 2009 Last Revised: 16 Dec 2009
Daniel N. Erasmus
Thomas Jefferson School of Law
Downloads287(101,185)

6. How Robust Is Your Structured Finance Transaction?
Thomas Jefferson School of Law Research Paper No. 1491359
Number of pages: 19 Posted: 20 Oct 2009 Last Revised: 21 Jun 2011
Daniel N. Erasmus
Thomas Jefferson School of Law
Downloads225(129,959)

7. A Summary of How Partnerships Are Taxed in Terms of International Law and Convention: An Entity or Transparent For Tax Purposes?
Thomas Jefferson School of Law Research Paper No. 1485907
Number of pages: 8 Posted: 09 Oct 2009 Last Revised: 15 Dec 2009
Daniel N. Erasmus
Thomas Jefferson School of Law
Downloads220(132,855)

8. Let’s Hope the New OECD Guidelines on Money Laundering Will Not Create More Unnecessary Tax Auditing
Thomas Jefferson School of Law Research Paper No. 1486429
Number of pages: 13 Posted: 11 Oct 2009 Last Revised: 20 Jun 2011
Daniel N. Erasmus
Thomas Jefferson School of Law
Downloads191(151,744)

9. Transfer Pricing in South Africa: Constitutional or Unconstitutional?
Thomas Jefferson School of Law Research Paper No. 1481223
Number of pages: 85 Posted: 04 Oct 2009 Last Revised: 20 Jun 2011
Daniel N. Erasmus
Thomas Jefferson School of Law
Downloads171(167,529)

10. An Analysis of Challenging the Commissioner’s Discretionary Powers Invoked in Terms of Sections 74A and 74B of the Income Tax Act 58 of 1962, in Light of the Constitution of the Republic of South Africa 108 of 1996
Number of pages: 278 Posted: 20 Apr 2014 Last Revised: 22 Apr 2014
Daniel N. Erasmus
Thomas Jefferson School of Law
Downloads149(188,422)

11. Comments on IASB Income Tax Accounting Exposure Draft ED/2009/02
Thomas Jefferson School of Law Research Paper No. 1481524
Number of pages: 9 Posted: 02 Oct 2009 Last Revised: 20 Jun 2011
Daniel N. Erasmus
Thomas Jefferson School of Law
Downloads106(244,377)

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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