Archive | January, 2015

S.Africa: Confusion regarding interpretation on tax (VAT) issues

Confusion regarding interpretation DLA Cliffe Dekker Hofmeyr Heinrich Louw South Africa January 23 2015 An interesting judgment was handed down in the Tax Court on 9 December 2014 in the matter of AB CC v The Commissioner of the South African Revenue Service (VAT case number 1005, as yet unreported). In this matter, a registered vendor for […]

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Posted in Africa, SADC, South Africa0 Comments

S.Africa: Transfer pricing documentation requirements due to change

  Transfer pricing documentation requirements due to change   Hogan Lovells Michiel Els South Africa January 21 2015 The Davis Committee has made certain recommendations relating to transfer pricing and documentation in its report on the OECD’s Base Erosion and Profit Shifting (BEPS) Action Plan. We are aware that the current transfer pricing practical guidelines, […]

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Posted in SADC, South Africa, Transfer Pricing0 Comments

S.Africa: Relationship between a VAT vendor and SARS

Relationship between a VAT vendor and SARS DLA Cliffe Dekker Hofmeyr Heinrich Louw South Africa January 16 2015 The Supreme Court of Appeal (SCA) recently handed down judgment in the matter of Director of Public Prosecutions, Western Cape v Parker (103/14) [2014] ZASCA 223 (12 December 2014).  In this matter a close corporation, being a registered vendor […]

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Posted in SADC, South Africa0 Comments

S.Africa: Tax Case – No evidence justifying penalty

No evidence justifying penalty DLA Cliffe Dekker Hofmeyr South Africa January 16 2015 On November 18 2014 the Tax Court ruled on AB (Pty) Ltd v The Commissioner for the South African Revenue Service (Case 1132, as yet unreported). Facts In this matter the South African Revenue Service (SARS) audited and assessed a vendor in respect of […]

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Nigeria: Tax Appeal Tribunal says withholding tax is due on dividends from gas profits – January 2015

Tax Appeal Tribunal says withholding tax is due on dividends from gas profits January 2015 In brief The Tax Appeal Tribunal (TAT) has ruled in favour of the Nigerian tax authority to levy withholding tax on dividends paid out of gas profits by an upstream petroleum company. The judgement takes a simple view of a rather complex […]

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Posted in Africa, FP News, Nigeria, West Africa0 Comments

South Africa: An update on tax avoidance principles in South Africa – January 2015

An update on tax avoidance principles in South Africa – January 2015 By Ernest MaraisB.Comm LLB (University of Stellenbosch, South Africa/ Maastricht University, Netherlands)Admitted Attorney in the High Court of South Africa and edited by Prof Dr Daniel N.Erasmus BA (Wits) BProc (UNISA) H Dip Tax (Wits) PhD (University KwaZulu-Natal) Admitted Attorney in the High […]

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South Africa: Fiscal legislation interpretation

Interpretation of fiscal legislation DLA Cliffe Dekker Hofmeyr South Africa January 9 2015 Introduction In Commissioner SARS v Bosch (394/2013) [2014] ZASCA 171 (November 19 2014), the Supreme Court of Appeal dealt with the fiscal consequences of a deferred delivery transaction. The judgment is important not only in the context of the meaning of simulation, but also […]

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Angola: Tax system

Overview of Angolan Tax System Rogério Fernandes Ferreira, Mónica Respício Gonçalves, Marta Machado de Almeida, José Mègre Pires, Francisca de Landerset Gomes RFF & Associados, Lisbon Rogério Fernandes Ferreira is Founding Partner, Mónica Respício Gonçalves is Senior Associate, Marta Machado de Almeida is Senior Associate, José Mègre Pires is Associate and Francisca de Landerset Gomes […]

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