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Emerging Trends in Transfer Pricing

Article published in SAIT, Tax Talk Magazine, Issue 103 November/ December 2023

Transfer pricing (TP) disputes have always posed challenges to multinational enterprises (MNEs) and tax authorities. The interpretation and implementation of arm’s length principles, the backbone of TP regulations, have led to an increasing number of TP disputes across the globe. This article considers emerging trends, emphasising the critical role of TP expert witnesses in any TP dispute.

The significance of TP expert witnesses in TP disputes

A central theme in any TP dispute resolution process is the selection and preparation of a TP expert witness. Such an expert is often called upon to lend their expertise during the trial; however, their participation is required very early in the TP dispute process to aid in finding workable resolutions.

Selecting the right TP expert witness

The onus of proving the arm’s length price rests with the taxpayer. It is crucial to choose an expert who possesses the requisite technical knowledge and the capability to present findings credibly in a court environment. Whereas there are many TP specialists globally, only a handful have the experience to serve as an effective expert in such a setting. A list of key considerations in selection follows. >>> Click here to download the full article >>>

CHECK OUT THESE POSTGRADUATE PROGRAMMES IN INTERNATIONAL TAXATION AND TRANSFER PRICING:

PROGRAMMES IN INTERNATIONAL TAXATION

Postgraduate Certificate – 6-month Course
Postgraduate Diploma – 1 Academic Year
Master (MSc) – 2 years (dissertation only if you have an existing PG-D from I/I/T/F)
Contact our Education Consultant, James Steinhauer, at tp@informaconnect.com or call him at +44 (0) 208 052 2710.

PROGRAMMES IN TRANSFER PRICING

Postgraduate Certificate – 6-month Course
Postgraduate Diploma – 1 Academic Year
Master (MSc) – 2 years (dissertation only if you have an existing PG-D from I/I/T/F)
Contact our Education Consultant, Ben Price, at tp@informaconnect.com or call him at +44 (0) 208 052 2710.

* All programmes are delivered by I/I/T/F Academy of Tax Law and validated and certified by Middlesex University, London. InformaConnect Ltd is the programme partner.

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

Transfer Pricing

International Tax

South African Tax Law

Mechanics of Conducting a TP Trial

Mechanics of Leading Tax Teams

Mechanics of Indirect Taxation

Mechanics of Tax Risk Management

Mastering Tax Dispute Resolution in South Africa

Emerging Trends in Transfer Pricing

Table of Contents

CHECK OUT THESE POSTGRADUATE PROGRAMMES IN INTERNATIONAL TAXATION AND TRANSFER PRICING:

PROGRAMMES IN INTERNATIONAL TAXATION

PROGRAMMES IN TRANSFER PRICING