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IN PARTNERSHIP WITH GTC GLOBAL
Global Tax Controversy Exams
Developed with Global Tax Controversy (GTC) for transfer pricing specialists confronted with tax audits, disputes and court procedures. Four exams, each building on the last: Exams 1 and 2 are open for enquiries now, Exam 3 and Exam 4 are coming soon.
The Four Exams
Global Tax Controversy is certification built around what you can do in a real dispute. Each exam certifies one specific skill and earns its own credential, assessed on real litigation and live board-level scenarios. Take the full track, or take the exams that fit your role.
GTC EXAM 1 - FOUNDATIONS
Available Now
Foundations of Global Tax Controversy
The Core module builds the foundational vocabulary and process knowledge that every later GTC module assumes is already in place: how transfer pricing disputes arise, how tax authorities examine and pursue them, how a company puts itself in a defensible position before an audit ever starts, and how to argue a defensible position against anti-abuse challenges using real litigation as the test bed.
Key Topics Covered
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TP Audit & Examination Process
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Tax Control & Governance
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BEPS & Value Creation
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Anti-Abuse Law & Treaty Application
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Risk, Adjustments & Arm's-Length Defense
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Case-Law Based Defense (applied skill)
Ideal for: Tax professionals new to controversy, advisors building foundational knowledge.
GTC EXAM 2 - CAPITA SELECTA
Available Now
Capita Selecta & Advanced Compliance
Building on the Core module's foundations (Exam 1), Capita Selecta takes participants into four of the most pressing themes in transfer pricing and tax controversy today. Each theme is grounded in current enforcement trends and real court decisions from around the world, giving participants a practical, up-to-date view of how tax disputes actually unfold and how leading practitioners are responding.
Key Topics Covered
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Anti-Abuse: Policy v. Practice
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The Need for Alternative Dispute Resolution
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Criminal and Administrative Tax Risk
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Landmark TP Cases & the Arm's-Length Principle
Ideal for: Tax and transfer pricing professionals who want to move beyond the fundamentals and understand how controversy actually plays out in practice, informed by live case law, cross-border comparison, and practitioner experience.
GTC EXAM 3 - JUDICIAL ANALYTICS
Coming Soon
Judicial Analytics and Dispute Comparison
Exam 3 tests the candidate's ability to work with a pool of court cases the way a controversy team would: identifying which cases actually belong together around a shared point of conflict, and pulling out the arguments that matter for that conflict rather than reproducing a case in full. It is a hybrid exam: the candidate works with AI tools to select and organize cases, and is assessed on the judgment applied at each step, not on manual case knowledge alone.
Key Topics Covered
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Theme construction and case selection across a 25-case transfer pricing dispute pool
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Building / identifying conflict themes (e.g. DEMPE/intangible valuation, intercompany financial transactions, commodity pricing) around genuine shared legal or economic issues
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Extracting supporting and opposing arguments per theme
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Working with AI tools to search, organize, and evaluate case material
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Bonus component: ranking arguments
Ideal for: Candidates who want to work with a case pool the way a controversy team would, identifying which cases genuinely belong together rather than memorizing individual cases, and who want to sharpen their use of AI tools for research and organization.
GTC EXAM 4 - BOARDROOM MASTER
Coming Soon
Boardroom Communication and Strategy
Exam 4 does not test knowledge of transfer pricing law. It tests the ability to translate a technical tax dispute into language a board can act on. Unlike Exam 3, the candidate is not selecting cases or ranking legal arguments. Working from a single case, The Coca-Cola Co. v. Commissioner, the candidate must advise a board of directors, most of whom are not tax specialists, in layman's terms: what is happening, what is at stake, and what the board should decide.
Key Topics Covered
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The Coca-Cola Co. v. Commissioner case across five parts (A to E), from the original 10-50-50 royalty formula through the 2020 Tax Court decision and FY2024 uncertain tax position reporting
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Five board-level dilemmas: value chain and formula, IRS position change, investor disclosure, the judge's questions, reserve adequacy
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Translating technical TP positions such as DEMPE, CPM/TNMM, arm's length principle, and Section 482 into business language a board can act on
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Writing a boardroom note on two dilemmas plus direct advice to the board
Ideal for: Candidates who want to practice translating a technical tax dispute into language a board can act on, and who want to build the skill of turning legal positions into clear business questions.
Exams Pricing
GTC EXAM 1 - FOUNDATIONS
Foundations of Global Tax Controversy
Available Now
350€ + VAT
GTC EXAM 2 - CAPITA SELECTA
Capita Selecta & Advanced Compliance
Available Now
350€ + VAT
GTC EXAM 3 - JUDICIAL ANALYTICS
Judicial Analytics and Dispute Comparison
Coming Soon
500€ + VAT
GTC EXAM 4 - BOARDROOM MASTER
Boardroom Communication and Strategy
Coming Soon
500€ + VAT
Global Tax Controversy Exam Bundle
GTC EXAM 1 - FOUNDATIONS
GTC EXAM 2 - CAPITA SELECTA
GTC EXAM 3 - JUDICIAL ANALYTICS
GTC EXAM 4 - BOARDROOM MASTER
1700€ + VAT
1500€ + VAT
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