S.Africa: When to expect a transfer pricing interpretation note?

February 12, 2018

When to expect a transfer pricing interpretation note? 2018/19 South African National Budget Expectations By Billy Joubert, Deloitte. South African corporate taxpayers have, over the past few years, been subjected to a barrage of additional transfer pricing compliance requirements. These have included compulsory documentation requirements, the requirement to submit Country-by-Country (CbC) reports plus onerous additional […]

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S.Africa: Taxpayer wins case against SARS’ failure to issue a Letter of Findings at the conclusion of a tax audit

February 8, 2018

S.Africa: Taxpayer wins case against SARS’ failure to issue a Letter of Findings at the conclusion of a tax audit I am pleased to inform you that a recent tax case I argued in PE (with colleagues Strombeck Pieterse Attorneys) was won with costs against SARS. The case has been redacted due to it being […]

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US Tax Reform 2018 – GILTI and “deemed transition tax” for US taxpayer individuals and pass-through LLCs

January 31, 2018

US 2018 Tax Reform Bill H.R.1 sections 14201 and 14202 on GILTI US 2018 Tax Reform us-tax-reform-context-new-tax-concepts-and-impact-on-your-business-models A US taxpayer, if you own shares in a foreign company of more than 10% – major repercussions are in play now after the latest US tax reform amendments Published on February 1, 2018 Dr Daniel N Erasmus […]

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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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