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 »
Explore the arm’s length principle of transfer pricing in-depth with our comprehensive guide tailored for tax professionals and multinational executives.
Understanding the Arm’s Length Principle of Transfer Pricing: A Comprehensive Guide Read Post »
Learn about management fees in transfer pricing, including key aspects, challenges, and best practices to ensure compliance with tax regulations.
Understanding Management Fees in Transfer Pricing: Key Aspects and Best Practices Read Post »
Explore the key aspects and implications of the BlackRock HoldCo 5, LLC v HMRC case, focusing on transfer pricing and the unallowable purpose test.
Detailed analysis of the UK vs. Kwik-Fit transfer pricing case, its global implications, and the value of expert guidance in transfer pricing matters.
UK vs. Kwik-Fit Transfer Pricing Case: Implications for Multinationals Read Post »
In this short video, Renier van Rensburg highlights the complexities of transfer pricing interest on shareholder loans and related matters.
TRANSFER PRICING: INTEREST ON SHAREHOLDER LOANS AND RELATED MATTERS Read Post »
The Supreme Court ruled on the tax dispute between the Spanish tax authorities and CEPSA concerning the allocation of general management and administration expenses to CEPSA’s Permanent Establishment (PE) in Algeria.
CEPSA’s Transfer Pricing Case: Spain vs Compañía Española de Petróleos (CEPSA) Read Post »
This case examines the taxation of the domestic permanent establishment of a Hungarian corporation operating in Germany. The central issue revolves around the adjustment of profits under Section 1(5) of the Foreign Tax Act (AStG), specifically how the relationship between the Hungarian corporation and its German branch was treated for tax purposes.
The FG Düsseldorf judgment of May 12, 2023, revolves around the transfer pricing dispute of a multinational enterprise operating a pipeline network across Germany, Belgium, and the Netherlands. The court found that the defendant’s method of profit allocation did not align with the arm’s length principle and violated the existing double taxation treaties.
Germany vs “Z Pipeline”: Transfer Pricing Disputes in Multinational Operations Read Post »
Eaton Corporation, a global manufacturer of electrical and industrial products, faced significant tax disputes with the IRS regarding its transfer pricing practices. The disputes centered around the company’s Advance Pricing Agreements (APAs) with the IRS, which were intended to establish transfer pricing methodologies for transactions between Eaton and its subsidiaries. The APAs were canceled by the IRS, leading to a tax court case in 2017 and an appeal in 2022.
Eaton Corporation vs. IRS: Transfer Pricing Dispute Read Post »
The Ferragamo France transfer pricing case offers valuable insights for luxury goods companies. This landmark ruling highlights the complexities of transfer pricing in the high-end retail sector.
Ferragamo France Transfer Pricing Case: Key Lessons for Luxury Brands Read Post »
The Coca-Cola transfer pricing dispute is a landmark case between The Coca-Cola Company (TCCC) and the Internal Revenue Service (IRS). The case centers on the appropriate transfer pricing method to allocate profits between Coca-Cola’s U.S. parent company and its foreign subsidiaries. The IRS argued that Coca-Cola’s existing transfer pricing method resulted in underpayment of U.S. taxes, leading to a significant tax deficiency.
Coca-Cola vs. IRS: Landmark Transfer Pricing Dispute 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 |