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MECHANICS OF CONDUCTING A
TRANSFER PRICING TRIAL

With transfer pricing audits becoming increasingly aggressive and complex, multinational corporations are facing unprecedented scrutiny and litigation risk from revenue authorities worldwide.

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Start Date

26 November 2025

Apply By

25 November 2025

Duration

16 Weeks, part-time

Effort

6–10 hrs/week average*
*Student dependent

Format

Online – Recorded lectures, Prescribed Reading, Live Q&A Tutorials

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Programme Overview

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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

Upon successful completion of the programme, participants will be able to:

  • Identify tax risks and evaluate their impact on their organisation
  • Develop strategies to manage and mitigate identified risks
  • Understand the principles and practices of transfer pricing and its implications
  • Master the processes involved in resolving tax disputes - from initial engagement to litigation and settlement
COURSE AGENDA
  • 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.
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  • 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
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Frequently Asked Questions

This programme is ideal for:

  • C-Suite Executives,
  • Corporate leaders
  • Legal Counsel
  • Financial executives
  • 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.

Upon successful completion of the programme, participants will be able to:

  • Identify tax risks and evaluate their impact on their organisation
  • Develop strategies to manage and mitigate identified risks
  • Understand the principles and practices of transfer pricing and its implications
  • Gain insights into effective communication and negotiation with tax authorities
  • Master the processes involved in resolving tax disputes – from initial engagement to litigation and settlement

Additionally, there are significant benefits of attending – for both, businesses and individuals, as follows:

For Businesses:

  • Adopt the latest tax regulations and compliance strategies to meet tax obligations, reducing penalties and legal issues
  • Protect against unforeseen liabilities and maintain financial stability
  • Integrate tax risk considerations into broader strategic planning for informed decision-making
  • Minimise disruptions to business operations

For Individuals:

  • Career advancement opportunities and accreditation from Middlesex University
  • Comprehensive skills development in tax risk management, including regulations, risk assessment, and strategic planning
  • Prepare for leadership and advisory roles – guide senior management on tax risk management strategies
  • Gain global perspective and insights into international tax issues – prepare for roles in multinational companies and cross-border tax matters

The programme emphasises real-world applications through case studies, simulations, and interactive sessions, ensuring that learners can apply theoretical knowledge to practical scenarios. Additionally, the course covers the latest developments in tax regulations and compliance, preparing participants to respond proactively to changes in the tax landscape.

A unique aspect of this program is its focus on international tax issues, providing insights into regional and jurisdiction-specific challenges. This global perspective is complemented by the extensive expertise of your course director Prof. Dr. Daniel N. Erasmus, a renowned authority in tax risk management, who brings invaluable practical experience and knowledge to the course.

All attendees will 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 a variety of course materials including videos, case studies, and written UNITs
  • Flexibility – Access and study when and where convenient for you
  • Interaction – Meet like-minded participants on the online forum
  • Assessment – Check your understanding with online quizzes

Students rate AoTL 96.6%

“I felt supported with the live lectures and the pre-recorded material allowed me to complete the course on my schedule, which was perfect. The texts and resources given were excellent.”
L CoddingtonClyde & Co
“How do I rate if there are no improvements needed :)”
E BankovaNew York Times
“My most sincere thanks to you for supporting me throughout.  This was an excellent course!”
J BalasubramanianDanfoss
“This is an excellent course - I have learnt so much!”
M YidanaGhana Revenue Authority
“It’s a demanding course with a substantial workload, but it’s well structured and supported by excellent resources. An outstanding programme overall.”
R McClean-EllisFirst Sentier Investors
I’ve studied with many institutions and, frankly, lost the enjoyment. Studying with ATL changed that. The administrators are on top of everything, and the academic material is excellent. It is structured in a way that works for people with demanding jobs. This has been the best study experience I’ve had.
N CelliersNLC Admin

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Course Brochure IFF TP Trial

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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