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2018 South African Budget Speech

South Africa Report from our correspondent Lutando Mvovo, South Africa Budget for 2018-19 – direct taxation The Budget for 2018-19 was presented to Parliament by the Minister of Finance on 21 February 2018. Details of the Budget with respect to direct taxation, which, unless stated otherwise, will apply from 1 March 2018, are summarized below. […]

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US: GILTI onerous for non-C corporation CFC shareholders

GILTI rules particularly onerous for non-C corporation CFC shareholders McDermott Will & Emery USA February 9 2018 Summary The recently enacted tax reform legislation significantly expanded the application of Subpart F, including by adding a new inclusion rule for non-routine CFC income, termed “global intangible low-taxed income” (GILTI). The GILTI rules apply higher tax rates to […]

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

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

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

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

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

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

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OECD TPG 2010

OECD TPG TRANSFER PRICING GUIDELINES 2010

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TP and Mining in Africa – A Reference Guide for Practitioners

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.

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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