Archive | Transfer Pricing

Tax Intelligence

I wrote a book on tax risk management that includes tax and strategy. It is called TAX INTELLIGENCE and is available on Amazon. https://www.amazon.com/Tax-Intelligence-Habitual-Mistakes-Companies/dp/145006874X However, I am willing to send free pdf copies to those who request it – please send your requests todaniel@TaxRiskManagement.com. The book has been used in college tax classes on tax […]

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South Africa: The Implementation Of BEPS – How It May All Come Together

South Africa: The Implementation Of BEPS – How It May All Come Together Last Updated: 2 December 2015 Article by Esther Geldenhuys ENSafrica We are all aware of “base erosion and profit shifting” or “BEPS”. On 5 October 2015, the OECD released its final reports in connection with its BEPS Action Plan including its final […]

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Nigeria: Impacts of the OECD BEPS Project on companies operating in Nigeria

Impacts of the OECD BEPS Project on companies operating in Nigeria October 2015 by PwC, Nigeria In brief On October 5 2015, the Organisation for Economic Cooperation and Development (OECD) released its final Base Erosion and Profit Shifting (BEPS) package containing measures that will significantly change existing international tax rules. The report is the result […]

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Posted in Africa, Nigeria, SADC, South Africa, Transfer Pricing, West Africa0 Comments

S.Africa: South Africa to Reintroduce Pre-2011 CFC Rules

By Edwin Naidu July 31 — Changes proposed by South Africa’s National Treasury would subject controlled foreign companies operating in that country to the divisionary rules regarding their inbound and outbound sale of goods that were effective before the rules were amended in 2011. The move aims to combat profit shifting and protect the domestic […]

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Namibia: Transfer Pricing update July 2015

In Namibia, Transfer Pricing Guidance Unclear Even as Auditors Undergo Training What’s New: Namibia is training staff for a transfer pricing unit it is creating within the Large Taxpayers’ Office of its Inland Revenue Department. Context: Audit enforcement currently is spotty and guidance is unclear as Namibia has not stated its position on the use […]

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Transfer Pricing: Corporate LiveWire Round Table on TP in 2015

Transfer Pricing 2015 In our Transfer Pricing Roundtable we spoke with nine experts from around the world to discuss the recent regulatory changes and interesting developments in their jurisdiction. Our chosen experts analyse the different pricing methods currently being implemented and discuss the challenges posed by a recent explosion of rules and regulations surrounding base […]

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Transfer Pricing – Adv Diploma offered through the Thomas Jefferson School of Law

Dear Applicant, Transfer pricing has become a major problem with international multinationals, particularly in developing countries. Revenue services are becoming more skilled in the area of transfer pricing, and every year sees a dramatic increase in companies being required to engage with revenue services on transfer pricing. The International Institute for Tax & Finance (IITF), in association with Thomas Jefferson […]

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Africa: S.Africa and other similar jurisdictions – the AUDIT engagement letter

SURVIVING A TAX AUDIT UNDER THE TAX ADMINISTRATION ACT, 2011 Presented by Prof. Dr. D N ERASMUS Tel: 083 458 8422 or +1.561.568.7115 E-mail: daniel@TaxRiskManagement.com www.TaxRiskManagement.com Introduction Viking Pony Africa Pumps (Pty) Ltd t/a Tricom Africa v Hidro-Tech Systems (Pty) Ltd & another 2011 (1) SA 327 (CC) para [37]: …PAJA defines administrative action as […]

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Posted in Africa, Nigeria, SADC, South Africa, Transfer Pricing, West Africa, Zambia0 Comments

S.Africa: SARS Issues Binding Private Ruling on Cross Border Interest-Free Loan, Withholding Tax on Interest

South Africa Revenue Service Issues Binding Private Ruling on Cross Border Interest-Free Loan, Withholding Tax on Interest The South African Revenue Service (SARS) May 28 issued Binding Private Ruling (BPR) 192 on whether an adjustment made to taxable income or tax payable under Section 31 of the Income Tax Act No. 28 of 1962 can […]

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S.Africa: A South African tax official explains the approach of the South African Revenue Service’s to the transfer pricing treatment of intangibles

SARS Official Sees ‘Backwards’ Analyses Of Intangibles Transactions by Multinationals Development: A South African tax official explains the approach of the South African Revenue Service’s to the transfer pricing treatment of intangibles. Significance: The official says that many multinational groups first focus on selecting their comparables, and then analyze the role of intangibles in the […]

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