On successful completion of the programme, including the MSc research dissertation, you will command transfer pricing theory and its practical application. You will analyse complex fact patterns, design defensible policies, benchmark, and produce audit ready documentation. In practice, you will diagnose and resolve critical disputes, manage controversy from audit to litigation, and communicate with boards, advisors, and regulators, equipping you to engage with revenue authorities and international standard setting bodies.

Duration

24-48 months, part-time

Credits

180 University Credits

Effort

6–10 hrs/week average*
*Student dependent

Assessment

15,000-word dissertation

Format

Distance-based, scheduled supervisor
meetings

Award

MSc (Master’s), Middlesex
University

MSc (Stage 1+2+3) Overview

Exit Qualification: MSc (Master’s)

For the MSc award, you need to complete Stage 3, having completed the Postgraduate Diploma (Stages 1 + 2), or an equivalent award.

    • To successfully complete this stage, students are required to work towards the submission of a 15,000-word dissertation.
    • The aim of the dissertation is to develop a careful and detailed study of a proposed problem or concern in Transfer Pricing. By implementing the knowledge acquired from the PG-Diploma stage. Students are required to conduct sufficient research to consider and respond to the respective problem.
    • Stage 3 consists of introductory lectures that cover the essentials of topic selection and the guidance to a well-written proposal and a structured dissertation.
    • Each student will be appointed a supervisor and will be required to book at least three sessions of live online interaction with their supervisor for guidance during the writing of their dissertation.
 

The primary objective of the dissertation is to apply your Transfer Pricing knowledge through rigorous research, to explore open questions and expand practice in the field.

You will conduct a careful, detailed study of a defined problem in Transfer Pricing, using learning from Stages 1 and 2 to frame the issue, gather and evaluate evidence, and deliver a clear, defensible answer.

A further goal is to analyse the findings deeply, generating new questions, concepts, and insights for Transfer Pricing practice.

Learning Outcomes

On successfully completing this module, the student will be able to:

  • Engage in systematic discovery and critical review of appropriate and relevant information sources within the practice area of Transfer Pricing.
  • Appropriately apply qualitative and/or quantitative evaluation processes to original information/ data within the practice area.
  • Understand and apply ethical standards of conduct in the collection and evaluation of data and other resources within the practice area.
  • Gain in-depth knowledge of the selected dissertation topic, and the relevance thereof in terms of the broader Transfer Pricing arena.
  • Equate the empirical challenges and be able to deal with practical research problems (e.g., collecting, manipulating and analysing data).
  • Develop the ability to design and manage a Transfer Pricing project and apply what has been learned to real-world scenarios.
  • Learn how to deal with the complex inter-relationships of real-world processes.
  • Hone the skills in interpersonal communication, data collection and analysis, report writing, and effective time management, all of which are critical in the extremely demanding and ever-changing world of Transfer Pricing.
  1. Develop the ability to design and manage a Transfer Pricing project and link its subject matter to other taxation knowledge bodies and apply what has been learned to real-world scenarios.
  2. Learn how to deal with the complex inter-relationships of real-world processes.
  3. Hone the skills in interpersonal communication, data collection and analysis, report writing, and effective time management are critical in the highly demanding and ever-changing world of Transfer Pricing.
  1. Perform an appropriate comparability analysis once a transaction has been delineated and carry out the required adjustments.
  2. Apply the comparability factors to each of the nine steps in a comparability analysis. 
  3. Determine Transfer Pricing on Intra-Group Services as per the OECD guidelines.
  4. Verify the arm’s length charge for intra-group services and low value-adding intra-group services.
  5. Analyse intangible transactions to apply the arm’s length principle to such transactions and implement any adjustments to these intangible transactions to adhere to the OECD guidelines for intangible transactions.

The assessment scheme consists of the following:

Dissertation (100 Marks): A 15,000-word dissertation to be submitted.

Students must submit their final dissertations on their chosen research topics. Feedback will be given throughout the research project period from approval of the topic until submission.

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PG-Cert | PG-Dip | MSc

Course Brochure PG-TP

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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