How To Deal With PE Risks In Practice post BEPs? – A 5-step Approach

January 12, 2018

How To Deal With PE Risks In Practice Post BEPS? – A 5-step Approach In an attempt to close the loopholes of the existing PE definition through BEPS Action 7, the OECD has, inadvertently, also lowered the threshold for the classification of the local business activities of a foreign enterprise as a PE of such […]

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OECD TPG 2017

January 10, 2018

OECD TPG Transfer Pricing Guidelines for Multinational Enterprises and Tax Administration July 2017

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OECD TPG 2010

January 10, 2018

OECD TPG TRANSFER PRICING GUIDELINES 2010

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TP and Mining in Africa – A Reference Guide for Practitioners

January 10, 2018

TP Transfer pricing in mining-with-a-focus-on-Africa-a-reference-guide-for-practitioners-Web

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For a road map of where to find key provisions in the final House-Senate bill, read Bloomberg Tax’s analysis.

December 23, 2017

For a road map of where to find key provisions in the final House-Senate bill, read Bloomberg Tax’s analysis.

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US: Trump Signs Tax Bill, and a methods-based analysis

December 22, 2017

Trump Signs Tax Bill Lowering Corporate, Individual Rates Posted December 22, 2017, 11:01 A.M. ET By Kaustuv Basu,Laura Davison and Allyson Versprille President Donald Trump signed the Republican tax bill into law, enacting the measure GOP lawmakers are pointing to as their No. 1 achievement during the first year of the administration. The bill (H.R. 1) cuts taxes […]

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Latest OECD Model Tax Convention released – 19 December 2017

December 19, 2017

OECD Model Tax Convention 2017 The latest edition of the OECD Model Tax Convention has been released today, incorporating significant changes developed under the OECD/G20 project to address base erosion and profit (BEPS). The OECD Model Tax Convention, a model for countries concluding bilateral tax conventions,  plays a crucial role in removing tax related barriers […]

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S.Africa: No trade, no deduction: Tax Court issues Section 11(a) judgment

December 19, 2017

No trade, no deduction: Tax Court issues Section 11(a) judgment   Cliffe Dekker Hofmeyr South Africa December 15 2017 On April 20 2017 the Tax Court issued its decision in X Group (Pty) Ltd v The Commissioner for the South African Revenue Service (SARS).(1) The case concerned X Group’s(2) claim for R90 million as an expense or loss during the […]

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Africa tax in Brief

November 29, 2017

Africa tax in Brief by Celia Becker Africa regulatory and business intelligence | executive cbecker@ENSafrica.com cell: +27 82 886 8744 African Tax Administration Forum launches transfer pricing risk assessment toolkit During the International Conference on Tax in Africa held in Abuja from 26 to 28 September 2017, the African Tax Administration Forum launched its “Toolkit for […]

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South Africa: Relocating and emigrating from South Africa

November 28, 2017

Relocating from South Africa? Key steps to undertake in the emigration process ENSafrica South Africa November 22 2017 There are a number of considerations when relocating to another country that involve much more than a mere physical departure and the taking up of permanent residence in a foreign country. In South Africa, an individual will continue to […]

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