Archive | April, 2015

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

Cook Islands: FATCA’s impact – this paper applies to many other offshore centres

April/May 2015[1]   Impact of FATCA on Cook Islands Entities[2] TABLE OF CONTENTS Background The key differences between FATCA and IGA Models 1 and 2 What does FATCA Mean for Cook Island Entities When Will a CI Entity be Classified as a Foreign Financial Institution Hedge Funds and Private Equity Funds CI Managers and Advisors […]

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USA Supreme Court: Principles applicable in Africa

21 April 2015 US Supreme Court finding. Rodriguez v. United States, No. 13-9972. Police violated the Fourth Amendment when they extended a traffic stop in order to conduct a dog sniff when there was no reasonable suspicion that justified holding the motorist any longer after the officers checked his license and issued a warning ticket […]

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S.Africa: Procedures governing objections and appeals

Procedures governing objections and appeals ENSafrica Dr Beric Croome South Africa April 14 2015 ENSafrica logo A taxpayer who receives an assessment from the Commissioner: South African Revenue Service with which they do not agree, is entitled to lodge an objection against that assessment and Chapter 9 of the Tax Administration Act, No. 28 of […]

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S.Africa: A field audit outside South Africa – can SARS do this?

A field audit outside South Africa – can SARS do this? ENSafrica Peter Dachs and Bernard Du Plessis South Africa April 14 2015 Tax authorities worldwide have certain powers aimed at enabling them to verify information submitted by taxpayers and the administration of tax legislation in their respective jurisdictions. Chapter 5 of the Tax Administration […]

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S.Africa: SARS Third Party Collection Notices issued against taxpayer creditors and Banks

https://www.youtube.com/watch?v=PS_mqYGSxkk

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Kenya: Tax Appeals Tribunal Bill 2013 – details

Kenya Tax Appeals Tribunal Bill 2013 – details 26 November 2013 Report from our correspondent Catherine Mutava, Nairobi ________________________________________ The Tax Appeals Tribunal Bill 2013 proposes to replace the current tax appeals system in Kenya. Details of the Bill are summarized below. General The Bill creates the Tax Appeals Tribunal (the “Tribunal”) whose role is […]

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Nigeria: Tax Summaries 25 March 2015

Nigeria: Nigeria Tax Summaries – 25 March 2015 Last Updated: 2 April 2015 Article by Taiwo Oyedele PwC Nigeria Have you ever been in a position where you needed to quickly confirm tax rates, filing deadlines, penalty for default, and other tax obligations? Even if you haven’t, don’t wait until you are stranded. Download and […]

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Seychelles: DRAFT Transfer Pricing rules – comments till 15 April 2015

http://www.src.gov.sc/resources/Rulings/2015/Ruling-2015-3.pdf Section 54 of the Business Tax Act 2009 states as follows: 54.(1) The Revenue Commissioner may, in respect of — (a) a transaction between businesses carried on by persons who are associates; or (b) a transaction between businesses carried on by the same person, distribute, apportion, or allocate income or gain and expenses between […]

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WHAT AMERICA GAINED AND SOUTH AFRICA LOST | The Truth About South Africa

WHAT AMERICA GAINED AND SOUTH AFRICA LOST | The Truth About South Africa.

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