Archive | August, 2015

S.Africa: PE Tax Ruling and Analysis update

By Edwin Naidu Aug. 25 — Foreign businesses rendering services in South Africa must consider and plan for the tax consequences relating to work undertaken in the country—or suffer the same fate as that of a U.S. multinational consulting firm penalized in a recent permanent establishment case before the country’s tax court, practitioners told Bloomberg […]

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Posted in Africa, South Africa0 Comments

S.Africa: United Kingdom: Major Victory for VWFS in Partial Exemption VAT Case

S.Africa: United Kingdom: Major Victory for VWFS in Partial Exemption VAT Case Posted on August 25, 2015. This UK VAT judgment will impact VAT apportionment cases in South Africa: United Kingdom: Major Victory for VWFS in Partial Exemption Case A recent significant decision concerns the victory of Volkswagen Financial Services (U.K.) Ltd (“VWFS”) in the […]

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S.Africa: proposed unilateral extension of prescription by SARS

proposed unilateral extension of prescription by SARS by Nicolette Smit, ENS Section 99 of the Tax Administration Act, 28 of 2011 (“Tax Admin Act”) regulates prescription in relation to tax assessments and provides for a three year prescription period in respect of income tax assessments and a five year prescription period in the case of […]

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Nigeria: PwC secures a favourable judgement on deemed income assessment August 2015

In brief In a recent decision, the Tax Appeal Tribunal (TAT) says a tax authority must act reasonably in the exercise of its discretion to assess a taxpayer based on deemed income (or best of judgment assessment). In the instant case, the TAT rules that a deemed income assessment cannot be based on general expectation […]

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Posted in Nigeria, West Africa0 Comments

South Africa: Inland Revenue Updates Guidelines on Valuation of Assets for Capital Gains Tax

South Africa Inland Revenue Updates Guidelines on Valuation of Assets for Capital Gains Tax The South African Inland Revenue Aug. 19 published Issue No. 3 of the Guide on Valuation of Assets for Capital Gains Tax (CGT) Purposes. The guideline explains and provides examples of how to determine the market value of assets: 1) on […]

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Posted in SADC, South Africa0 Comments

Its time to gear up on Transfer Pricing – please take a look at this Adv Dip in TP – http://www.iiribcfinance.com/event/Advanced-Diploma-in-Transfer-Pricing

Its time to gear up on Transfer Pricing – please take a look at this Adv Dip in TP – http://www.iiribcfinance.com/event/Advanced-Diploma-in-Transfer-Pricing You graduate from the Thomas Jefferson School of Law, San Diego, CA after a year.

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South Africa: Africa Tax In Brief (July 2015) Last Updated: 29 July 2015 Article by Celia Becker ENSafrica Most Read Contributor in South Africa, July 2015 ANGOLA: Special Contribution Regime for Foreign Technical Assistance and Management Services A Special Contribution Regime for Foreign Technical Assistance and Management Services was introduced through Presidential Legislative Decree number […]

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