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 »
Understand what a country-by-country report (CbCR) is in transfer pricing and why it’s crucial for multinational enterprises with this comprehensive guide.
What is a Country-by-Country Report (CbCR) in Transfer Pricing? Read Post »
Discover best practices for creating a local file as part of your transfer pricing documentation. This guide covers key elements, formatting, and compliance tips for tax professionals.
Creating a Local File in Transfer Pricing Documentation Read Post »
Explore the landmark Italy vs UFI Filters transfer pricing case, its implications for multinationals, and the importance of robust tax risk management.
Italy vs UFI Filters: Supreme Court Upholds Arm’s Length Pricing Read Post »
Explore the Dutch Supreme Court’s ruling in the X Holding transfer pricing case and its implications for multinational corporations and tax authorities worldwide.
X Holding Case: Dutch Supreme Court Rules on TP Dispute Read Post »
Discover best practices for creating a comprehensive transfer pricing master file to comply with documentation requirements for multinational enterprises and medium-sized businesses.
Creating a Master File for Transfer Pricing Documentation Read Post »
Detailed analysis of the France vs. SAP France transfer pricing case, its implications for multinationals, and preventative measures for better tax management.
Analysis of the Transfer Pricing Case: France vs. SAP France Read Post »
In-depth analysis of the landmark transfer pricing case between Colombia and INDEGA, its implications for multinationals, and how preventative measures like tax steering committees can help avoid such disputes.
Transfer Pricing Case: Colombia vs. Industria Nacional de Gaseosas S.A. (INDEGA) Read Post »
Understand the importance of functional analysis in transfer pricing and how to conduct it effectively for multinational enterprises and medium-sized businesses.
Guide to Functional Analysis in Transfer Pricing Read Post »
Explore the in-depth analysis of the landmark transfer pricing case between Czech Republic and AHI Oscar S.R.O., highlighting its significance for multinationals and revenue services.
Transfer Pricing Case: Czech Republic vs. AHI Oscar S.R.O. Read Post »
Learn what essential elements should be included in transfer pricing documentation to ensure compliance and mitigate risks.
Essential Components of Transfer Pricing Documentation Read Post »
Learn what an arm’s length price is, with examples and importance for tax compliance. Essential guide for tax professionals and multinational organizations.
Arm’s Length Price Examples: A Comprehensive Guide 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 |