Archive | October, 2017

S.Africa: Groundbreaking decision for mining companies

Groundbreaking decision for mining companies PLUS an important determination: Sars has argued that the high court did not have jurisdiction in the matter, and that it should have been heard by the tax court. The court disagreed and found that it has jurisdiction to hear and determine tax cases turning on legal issues. Firms entitled to […]

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Advanced Diploma in TP by Thomas Jefferson School of Law

organised by www.IITF.net, promoted by INFORMA, London Certificate by Thomas Jefferson School of Law Hi, The deadline to submit your application for an Advanced Diploma in Transfer Pricing is fast approaching. Develop an in-depth and practical understanding of transfer pricing as you learn about the latest tax treatments of complex transactions and policy developments that companies need to regularly deal […]

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Transfer Pricing in mining with a focus on Africa by Steef Huibregtse (TP Associates) and others

http://documents.worldbank.org/curated/en/801771485941579048/pdf/112346-REVISED-Dated-Transfer-pricing-in-mining-with-a-focus-on-Africa-a-reference-guide-for-practitioners-Web.pdf PART OF THE PRECIS: The World Bank Group, led by the Energy and Extractives Global Practice, has been at the forefront of offering advice on good practices, as well as on undertaking diagnostic visits and building capacity of developing countries on mineral tax administration. It has adopted a phased approach—wherein it undertakes research and […]

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Transfer Pricing Toolkit to Give African Tax Authorities Clout

Transfer Pricing Toolkit to Give African Tax Authorities Clout • Interventions have brought in over $120m tax revenue in two years • Toolkit empowers authorities to assess transfer pricing risks By Marcia Klein The African Tax Administration Forum has published a toolkit (https://www.ataftax.org/en/products-services/technical-assistance/transfer-pricing-tp) for transfer pricing and risk assessment in the African mining sector, with the help of Germany’s Federal […]

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SEC Roundup: Various MNEs Report IRS Transfer Pricing and related Adjustments and the SASOL tax case in S.Africa

SEC Roundup: Various MNEs Report IRS Transfer Pricing and related Adjustments By Sony Kassam Dell Technologies Inc., a Texas-based information technology company, reported that the IRS Office of Appeals is reviewing its federal income tax returns for 2007-09 and that the agency proposed transfer pricing adjustments for those years, according to a filing with the Securities and Exchange […]

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SEC Roundup: Various MNEs Report IRS Transfer Pricing and related Adjustments

By Sony Kassam Dell Technologies Inc., a Texas-based information technology company, reported that the IRS Office of Appeals is reviewing its federal income tax returns for 2007-09 and that the agency proposed transfer pricing adjustments for those years, according to a filing with the Securities and Exchange Commission. In addition, Analogic Corp. reported that it accrued […]

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S.Africa: MFN clause in RSA and Netherlands DTA and some additional info

Read the latest PwC Synopsis on the case first: http://www.pwc.co.za/en/assets/pdf/synopsis-september-2017.pdf?utm_medium=email&utm_source=sharpspring&sslid=MzIxMDA2tjA0NDEzAAA&sseid=MzQ1NzM3MbAwswAA&jobid=84ad69aa-fb01-4f43-a4a9-0182ea1b4103 The Most Favoured Nation clause appears in the General Agreement on Trade (GATT) and General Agreement on Trade and Services (GATS) of the WTO. Most nations are members of the WTO, and the agreement would be considered to be customary international law. The MFN and […]

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BEPS (2017) Action 13 CbC Reporting Handbook on Effective Tax Risk Assessment

BEPS (2017) Action 13 CbC Reporting Handbook on Effective Tax Risk Assessment OECD (2017), Country-by-Country Reporting: Handbook on Effective Tax Risk Assessment, OECD, Paris. OBTAIN YOUR COPY HERE: http://www.oecd.org/tax/beps/country-by-country-reporting-handbook-on-effective-tax-risk-assessment.htm Table of contents  Abbreviations and Acronyms ………………………………………………………………………………………………………..7  Chapter 1 Introduction and Background………………………………………………………………………………………9  Chapter 2 The Role of Tax Risk Assessment in Tax Administration…………………………………………….15  Current developments in […]

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S.Africa: Does a tax audit constitute “administrative action” under PAJA

This is a reprint of an earlier article – but still very relevant today: What follows is a discussion that is relevant to South African tax law, read with the Constitution and administrative law, which may apply in various other African jurisdictions as well: Introduction Viking Pony Africa Pumps (Pty) Ltd t/a Tricom Africa v Hidro-Tech Systems […]

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