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Author name: Dr Daniel N Erasmus

Eaton Corporation vs. IRS: Transfer Pricing Dispute

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 »

UPS Asia Group Pte. Ltd. Case: Transfer Pricing and Permanent EstablishmentUPS Asia Group Pte. Ltd. Case:

The case of UPS Asia Group Pte. Ltd. vs. Asstt. Commissioner of Income Tax revolves around the interpretation of whether the applicant had a “Business Connection” in India and a “Permanent Establishment” (P.E.) under the India-Singapore Double Taxation Avoidance Agreement (DTAA). The Income Tax Appellate Tribunal (ITAT) ruled in favour of UPS Asia Group, stating that when the Indian Associated Enterprise (A.E.) is remunerated at arm’s length price, no further profit attribution is required, making the existence of a P.E. tax-neutral.

UPS Asia Group Pte. Ltd. Case: Transfer Pricing and Permanent EstablishmentUPS Asia Group Pte. Ltd. Case: Read Post »

Transfer Pricing Dispute Between Australia and Glencore Investment Pty Ltd

Glencore Australia (CMPL) sold copper concentrate produced in Australia to its Swiss parent, Glencore International AG (GIAG).

The tax authorities found that the price paid by Glencore International AG to Glencore Australia for the copper concentrate in the relevant years, according to a price-sharing agreement, was less than the price that might reasonably be expected to have been paid in an arm’s length dealing between independent parties.

Transfer Pricing Dispute Between Australia and Glencore Investment Pty Ltd Read Post »

Lexel AB v Sweden (Skatteverket): CJEU Ruling on Interest Deductions and Freedom of Establishment

In Lexel AB v Skatteverket (Case C‑484/19), the Court of Justice of the European Union (CJEU) ruled that Swedish tax legislation, which denied Lexel AB the right to deduct interest payments made to a group company located in another EU Member State (France), infringed upon the freedom of establishment protected under Article 49 TFEU.

Lexel AB v Sweden (Skatteverket): CJEU Ruling on Interest Deductions and Freedom of Establishment Read Post »

Coca-Cola vs. IRS: Landmark Transfer Pricing Dispute

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.

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Anwar & Co. v. CIT: Understanding Permanent Establishment in International Taxation

The case of Anwar & Co. v. CIT is a landmark ruling by the Supreme Court of India that delves deep into Permanent Establishment (PE) and its implications for cross-border taxation. The court was tasked with determining whether the activities of a foreign company in India, facilitated through Anwar & Co., constituted a PE, thereby attracting Indian tax liabilities.

Anwar & Co. v. CIT: Understanding Permanent Establishment in International Taxation Read Post »

GlaxoSmithKline v. CIR (Philippines)

In GlaxoSmithKline (GSK) Philippines, Inc. v. Commissioner of Internal Revenue (CIR), the Supreme Court of the Philippines upheld a tax deficiency assessment against GSK Philippines, emphasizing the importance of adhering to transfer pricing regulations. The case was a landmark decision in 2018, underscoring the significance of the arm’s length principle in determining taxable income for multinational corporations.

GlaxoSmithKline v. CIR (Philippines) Read Post »

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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