The Dow Chemical Canada case underscores the complex interplay between tax law, administrative discretion, and jurisdictional issues in transfer pricing disputes.
Dow Chemical Canada ULC v. The King: Tax Court Jurisdiction in Transfer Pricing Disputes Read Post »
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 »
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 »
In the landmark case of Poulter v CSars the Western Cape High Court clarified an essential aspect of taxpayers’ rights in South Africa. This case revolved around whether a taxpayer can be represented by a non-legal practitioner in the Tax Court, significantly impacting how taxpayers can defend themselves in tax-related disputes.
Poulter vs SARS: Taxpayer’s Right to Non-Legal Representation 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 »
This case revolves around the European Commission’s appeal against the General Court’s decision to annul the Commission’s ruling that Ireland granted Apple unlawful state aid through favourable tax rulings.
Apple vs. European Commission Read Post »
The Supreme Administrative Court (SACC) of the Czech Republic annulled the judgment of the Regional Court in Hradec Králové, which had previously annulled the tax assessment decision of the Odvolací finanční ředitelství against Stora Enso Wood Products Ždírec s.r.o.
Stora Enso Wood Products vs Czechia 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 |