Archive | June, 2015

Mauritius: Impact of FATCA on Mauritius Entities

Impact of FATCA on Mauritius Entities Stephen V. Scali Conyers Dill & Pearman Stephen V. Scali is Head of Mauritius Office at Conyers Dill & Pearman I. Background FATCA is a U.S. federal law that aims to reduce tax evasion by U.S. persons. FATCA has significant extraterritorial implications and, most notably, requires foreign financial institutions […]

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Posted in Africa, SADC0 Comments

S.Africa: Taxation of Interest – The Complex Web

Taxation of Interest in South Africa—The Complex Web The number of provisions contained in the Income Tax Act 1962 (“the Act”) which deal with tax treatment of interest income and interest expenditure have gradually increased over time. There are numerous aspects to be borne in mind by resident and foreign companies when considering the income […]

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Posted in Africa, SADC, South Africa0 Comments

Botswana Becomes Eighth WTO Member To Approve Trade Facilitation Agreement

Botswana Becomes Eighth WTO Member To Approve Trade Facilitation Agreement (“TFA”) Botswana has ratified the World Trade Organization’s Trade Facilitation Agreement, making it the first nation on the African continent to do so. The TFA instructs WTO members to improve their customs procedures and expedite the movement, release and clearance of goods, among other commitments. […]

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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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Posted in Africa, Courses, Transfer Pricing0 Comments

USA: “IRS Makes Changes to Offshore Programs; Revisions Ease Burden and Help More Taxpayers Come into Compliance“

The new revisions to the US offshore voluntary disclosure program, which we posted on 6/18/14 “IRS Makes Changes to Offshore Programs; Revisions Ease Burden and Help More Taxpayers Come into Compliance“, now provides for an increased 50% FBAR Penalties for ‘Willful’ Non-Disclosers. This group includes those individuals who have offshore bank accounts with a foreign […]

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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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Posted in Africa, Courses, Transfer Pricing0 Comments

Treaty between Mauritius and South Africa enters into force

Treaty between Mauritius and South Africa enters into force On 28 May 2015, the Mauritius – South Africa Income Tax Treaty (2013) entered into force. The treaty generally applies from 1 January 2016. From this date, the new treaty generally replaces the Mauritius – South Africa Income Tax Treaty (1996). For details of the new […]

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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

Nigeria: A Landmark TAT decision in a VAT case on imported services

PwC secures a Landmark TAT decision in a VAT case on imported services In brief On 10 June 2015, the Tax Appeal Tribunal (TAT) sitting in Abuja held that foreign companies providing services outside Nigeria to Nigerian companies are not carrying on business in Nigeria for the purposes of the Nigerian Value Added Tax (VAT). […]

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Posted in Africa, Nigeria, West Africa0 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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Posted in Africa, SADC, South Africa, Transfer Pricing0 Comments