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OECD Multilateral Convention to Prevent BEPS: Implementation Guide and Initial Thoughts

OECD MULTILATERIAL CONVENTION TO PREVENT BEPS The final version of the OECD Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) was published at the end of November 2016, and the signing ceremony took place in Paris on 7 June 2017, during which 68 countries covering 69 jurisdictions […]

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South Africa: Foreign Consultants in SA, & the High Court hears certain Tax Cases

1. Foreign consultants and services in South Africa 2. The High Court is prepared to hear certain cases At TRM Daniel Erasmus Tax Court Practitioners (daniel@TaxRiskManagement.com) we have advocated successfully that the High Court is the correct forum to address certain tax issues, particularly on interpretation and procedural defects, in certain instances. 1. South African […]

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INDIA: Impact of the MLI on Indian Tax Treaties – this will be of interest on the effects of the MLI on other countries

Impact of the MLI on Indian Tax Treaties – this will be of interest to the effects of the MLI on other countries   Daksha Baxi and Ankit Namdeo Khaitan & Co. Mumbai (India) Daksha Baxi is an Executive Director and Ankit Namdeo is an Associate in the Direct Tax Team, Khaitan & Co. Mumbai (India) […]

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S.Africa: Groundbreaking decision for mining companies

Groundbreaking decision for mining companies PLUS an important determination: Sars has argued that the high court did not have jurisdiction in the matter, and that it should have been heard by the tax court. The court disagreed and found that it has jurisdiction to hear and determine tax cases turning on legal issues. Firms entitled to […]

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Advanced Diploma in TP by Thomas Jefferson School of Law

organised by www.IITF.net, promoted by INFORMA, London Certificate by Thomas Jefferson School of Law Hi, The deadline to submit your application for an Advanced Diploma in Transfer Pricing is fast approaching. Develop an in-depth and practical understanding of transfer pricing as you learn about the latest tax treatments of complex transactions and policy developments that companies need to regularly deal […]

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Transfer Pricing in mining with a focus on Africa by Steef Huibregtse (TP Associates) and others

http://documents.worldbank.org/curated/en/801771485941579048/pdf/112346-REVISED-Dated-Transfer-pricing-in-mining-with-a-focus-on-Africa-a-reference-guide-for-practitioners-Web.pdf PART OF THE PRECIS: The World Bank Group, led by the Energy and Extractives Global Practice, has been at the forefront of offering advice on good practices, as well as on undertaking diagnostic visits and building capacity of developing countries on mineral tax administration. It has adopted a phased approach—wherein it undertakes research and […]

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Transfer Pricing Toolkit to Give African Tax Authorities Clout

Transfer Pricing Toolkit to Give African Tax Authorities Clout • Interventions have brought in over $120m tax revenue in two years • Toolkit empowers authorities to assess transfer pricing risks By Marcia Klein The African Tax Administration Forum has published a toolkit (https://www.ataftax.org/en/products-services/technical-assistance/transfer-pricing-tp) for transfer pricing and risk assessment in the African mining sector, with the help of Germany’s Federal […]

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SEC Roundup: Various MNEs Report IRS Transfer Pricing and related Adjustments and the SASOL tax case in S.Africa

SEC Roundup: Various MNEs Report IRS Transfer Pricing and related Adjustments By Sony Kassam Dell Technologies Inc., a Texas-based information technology company, reported that the IRS Office of Appeals is reviewing its federal income tax returns for 2007-09 and that the agency proposed transfer pricing adjustments for those years, according to a filing with the Securities and Exchange […]

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SEC Roundup: Various MNEs Report IRS Transfer Pricing and related Adjustments

By Sony Kassam Dell Technologies Inc., a Texas-based information technology company, reported that the IRS Office of Appeals is reviewing its federal income tax returns for 2007-09 and that the agency proposed transfer pricing adjustments for those years, according to a filing with the Securities and Exchange Commission. In addition, Analogic Corp. reported that it accrued […]

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S.Africa: MFN clause in RSA and Netherlands DTA and some additional info

Read the latest PwC Synopsis on the case first: http://www.pwc.co.za/en/assets/pdf/synopsis-september-2017.pdf?utm_medium=email&utm_source=sharpspring&sslid=MzIxMDA2tjA0NDEzAAA&sseid=MzQ1NzM3MbAwswAA&jobid=84ad69aa-fb01-4f43-a4a9-0182ea1b4103 The Most Favoured Nation clause appears in the General Agreement on Trade (GATT) and General Agreement on Trade and Services (GATS) of the WTO. Most nations are members of the WTO, and the agreement would be considered to be customary international law. The MFN and […]

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