A creature of statute: A decision about the Tax Court’s power to increase understatement penalties – Cliffe Dekker Hofmeyr

March 22, 2019

In the recent judgment of Purlish Holdings (Proprietary) Limited v The Commissioner for the South African Revenue Service (76/18) [2019] ZASCA 04, the Supreme Court of Appeal (SCA) had to pronounce on the South African Revenue Service’s (SARS) entitlement to impose understatement penalties on Purlish Holdings (Proprietary) Limited (Taxpayer) and the quantum thereof. To this […]

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Posted in Africa, Courses, Events, FP Carousel, FP News, Nigeria, SADC, South Africa, Transfer Pricing, West Africa, Zambia

S.Africa: Your taxpayer rights – Tax Dispute Resolution principles

March 13, 2019

https://www.linkedin.com/feed/update/urn:li:activity:6511218979674169344/

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S.Africa: 20 February 2019 Budget – tax proposals

February 21, 2019

Budget speech tax proposals: http://www.treasury.gov.za/documents/national%20budget/2019/review/Annexure%20C.pdf SARS’ own tax guide: http://www.treasury.gov.za/documents/national%20budget/2019/sars/Budget%202019%20Tax%20Guide.pdf

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S.Africa: A diver’s quandary: The role of domestic law in interpreting double taxation agreements

February 19, 2019

Cliffe Dekker Hofmeyr In the international tax law arena, agreements for the avoidance of double taxation (DTAs) are, very simply, concluded between states with a view to prevent, mitigate or discontinue the levying of tax in respect of the same income, profits or gains or tax imposed in respect of the same donation under the […]

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SSRN Research Papers download – Tax Planning and other Papers to download

February 19, 2019

SSRN Research Papers Congratulations Dr Daniel N Erasmus You are currently in the top 10% of Authors on SSRN by all-time downloads. Check out your Research Papers on SSRN. https://papers.ssrn.com/sol3/cf_dev/AbsByAuth.cfm?per_id=990830 1. Tax Planning as Part of a Tax Risk Management ProcessThomas Jefferson School of Law Research Paper No. 1482423Number of pages: 88 Posted: 04 Oct 2009 Last Revised: […]

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Posted in Africa, Courses, Events, FP Carousel, FP News, Nigeria, SADC, South Africa, Transfer Pricing, West Africa, Zambia

TRANSFER PRICING BUSINESS MODELS

February 17, 2019

By Angela Sadang  |  January 27, 2017  |    Download PDF  Once the initial transfer pricing interviews (i.e. functional analysis interviews) have been conducted and the necessary data has been gathered, it is then time to describe the client’s business model. This means distinguishing the functions performed, the assets employed, and the risks assumed by the entities involved in intercompany […]

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S.Africa: Win for the employer: Judgment on the Employment Tax Incentive Act

February 16, 2019

By CDH Cliffe Dekker Hofmeyr – Louis Botha and Louise Kotze In the recent case of ABC (Pty) Ltd v The Commissioner for the South African Revenue Service (Case No 14426) (as yet unreported), the Tax Court was required to decide whether ABC (Pty) Ltd (Taxpayer) could claim the employment tax incentive (ETI) in terms of the Employment Tax […]

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Global Tax Alert: Dutch Supreme Court confirms dividend withholding tax exemption under treaty between South Africa and the Netherlands

February 6, 2019

DLA PIPER In our Global Tax Alert on February 5, 2018, we discussed the decision of the Dutch Court of Appeal (‘s-Hertogenbosch) which held that dividend distributions from Dutch entities to South African entities are effectively exempt from Dutch dividend withholding tax pursuant to the most favored nation (MFN) clause in the tax treaty between the Netherlands […]

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S.Africa: When must a reportable arrangement be disclosed to SARS?

February 6, 2019

By Ben Strauss, Cliffe Dekker Hofmeyr Attorneys Under the Tax Administration Act, No 28 of 2011 (TAA) persons who enter into certain types of transactions must report the details of those transactions to SARS. These types of transactions are called “reportable arrangements”. The list of transactions that must be reported are set out in s35(1) […]

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UN tax committee to update to key transfer pricing manual for developing countries

January 26, 2019

By Julie Martin, Editor, MNE Tax The next edition of the United Nations Practical Manual on Transfer Pricing for Developing Countries will include a new chapter on financial transactions, substantial revisions current guidance on the transactional profit-split method, and new material on centralized procurement functions, according to a newly-released UN document that summarizes the most recent meeting of the Committee of […]

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Posted in Africa, Events, FP Carousel, FP News, Nigeria, SADC, South Africa, Transfer Pricing, West Africa, Zambia