Archive | February, 2015

Nigeria: Tax Appeal Tribunal rules on the treatment of capital allowance clawback in a disposal of an oil asset

Tax Appeal Tribunal rules on the treatment of capital allowance clawback in a disposal of an oil asset February 2015 In brief In a recent decision, the Tax Appeal Tribunal (“Tribunal”) held that no capital allowance claw-back (balancing charge) should be computed on the disposal proceed relating to intangible assets on which no capital allowance […]

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Nigeria: The Rate Of Withholding Tax On Construction And Related Activities Has Been Reduced From 5% To 2.5%

Nigeria: The Rate Of Withholding Tax On Construction And Related Activities Has Been Reduced From 5% To 2.5% Last Updated: 25 February 2015 Article by Taiwo Oyedele PwC Nigeria The federal government has gazetted an amendment to the Withholding Tax Regulations 1997. The amendments have a commencement date of 1 January 2015. The changes introduced are: […]

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Posted in Africa, Nigeria, West Africa0 Comments

MIAMI TP CONFERENCE: OBSERVATIONS AT THE TP MINDS TRANSFER PRICING SUMMIT 2015 HELD IN MIAMI ON 24/25 FEBRUARY 2015

MIAMI TP CONFERENCE: OBSERVATIONS AT THE TP MINDS TRANSFER PRICING SUMMIT 2015 HELD IN MIAMI ON 24/25 FEBRUARY 2015 The main theme of the Transfer Pricing Conference was a look at the impact BEPS has on the transfer pricing environment. Specific areas that are notable and that were focused on were – Action 8 on […]

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Posted in Africa, Transfer Pricing0 Comments

Kenya: Guidance on Natural Resource Income Withholding Tax

Kenya Issues Guidance on Natural Resource Income Withholding Tax Feb. 25 — The Kenyan Revenue Authority (KRA) Feb. 20 released guidance on withholding tax on natural resource income, introduced under the Finance Act 2014 and effective Jan. 1, 2015. The guidance details what constitutes natural resource income, the taxpayer liability, the withholding rate and the […]

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S.Africa: TAA Requests for relevant material: A delicate balance between SARS’ powers and taxpayer’s rights

Requests for relevant material: A delicate balance between SARS’ powers and taxpayer’s rights Author: Jerome Brink (ENSafrica) The world economy is still in a fragile state and battling to gain momentum as many developed countries continue to feel the after-effects of the global financial crisis and several developing nations continue to grapple with inherent inefficiencies. South Africa […]

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Posted in Africa, SADC, South Africa0 Comments

S.Africa: Deemed loans under transfer pricing seen as a dividend declared on 1 January 2015

Deemed loans under transfer pricing seen as a dividend declared on 1 January 2015 Authors: Okkie Kellerman, Jens Brodbeck and Arnaaz Camay (ENSafrica) South African taxpayers who made a transfer pricing adjustment in previous years of assessment will be required to pay dividend tax at the end of 28 February 2015. Under the old transfer pricing rules, […]

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Posted in Africa, SADC, South Africa, Transfer Pricing0 Comments

S.Africa: A recap of the REIT provisions and the latest amendments thereto

A recap of the REIT provisions and the latest amendments thereto 24 February 2015 Author: Toinette Beckert (ENSafrica) The provisions in the Income Tax Act No. 58 of 1962 (“the Act”) pertaining to the taxation of Real Estate Investment Trusts (“REITs”) are contained in section 25BB and were introduced into the Act with effect from […]

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Posted in Africa, FP News, SADC, South Africa0 Comments

S.Africa: Imminent changes to transfer pricing documentation requirements in South Africa

Imminent changes to transfer pricing documentation requirements in South Africa 24 February 2015 Posted by: Author: Arnaaz Camay of ENS On 17 July 2013 the Minister of Finance appointed a tax review committee, headed by Judge Dennis Davis (the “Davis Committee”) to make recommendations for possible tax reforms in South Africa (“SA”). The Davis Committee […]

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S.Africa: Summary of the Davis Tax Committee’s BEPS Sub-committee General Report released December 2014

Summary of the Davis Tax Committee’s BEPS Sub-committee General Report released December 2014 by Peter Dachs of ENS Introduction This note provides a summary of the Davis Tax Committee’s (DTC) general report detailing the South African perspective of Base Erosion and Profit Shifting (BEPS).1 The Sub-committee’s interim report released during December 2014 is titled “Addressing […]

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S.Africa: TAA and Reportable arrangements – significant changes in pipeline

Reportable arrangements – significant changes in the pipeline 27 January 2015 Posted by: Author: Kyle Mandy   The Tax Administration Laws Amendment Bill 14 of 2014 (TALAB) proposes a number of important changes to the reportable arrangement provisions contained in Chapter 4 of the Tax Administration Act (TAA). However, it is important to also consider […]

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