Historical Evolution on Transfer Pricing and Value Creation

November 13, 2019

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Corporate tax planning developments in South Africa

November 13, 2019

ENSafrica A company is defined in the Income Tax Act, 58 of 1962 (the Income Tax Act) as including any association, corporation, body corporate or company incorporated in South Africa, and constitutes a person for tax purposes and is subject to, inter alia, income tax and CGT. For income tax purposes, a trust constitutes a person […]

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OECD and EU updates on TP related issues

November 13, 2019

OECD consults on “Pillar Two” global minimum tax proposal November 8, 2019 The OECD Secretariat today released a consultation document to assist in the design of a . . The OECD’s ‘Unified Approach” to digital taxation November 8, 2019 George L. Salis, Principal Economist & Tax Policy Advisor at Vertex, Inc., King of Prussia, Pennsylvania, […]

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Revenue Statistics in Africa 2019

November 13, 2019

The 2019 edition of the tax policy publication Revenue Statistics in Africa https://www.oecd.org/tax/tax-policy/revenue-statistics-in-africa-2617653x.htm will be launched on Tuesday, 19 November, during the African Union’s 13th Session of the Committee of Director Generals of National Statistics Offices. The report provides an overview of the main taxation trends from 1990 to 2017 in 26 African economies. This […]

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Monitoring and enforcing: Determining if MNEs pay their “fair share” of New Zealand tax.

November 12, 2019

The Inland Revenue document Multinational Enterprises Compliance Focus (2019) focuses on the base erosion and profit shifting (BEPS) measures implemented since the previous version of the document (2016) was released, and explains how compliance with these measures will be monitored and enforced to determine that MNEs pay their “fair share” of New Zealand tax. Overview of Inland […]

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TP Lecture week 2.2 – Legal Framework

November 10, 2019

Follow the curriculum – Reading: For a useful comparative tool on TP country-by-country, look at: https://www.lexology.com/navigator# and select the topic “transfer pricing” PWC International TP 2015-16 Kenya, page 641 Turkey, page 993 General ongoing reading as the courses advance, reading about 10 pages a week to gain an overview understanding: An Overview of Transfer Pricing by IBFD

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

TP Lecture week 2.1 – Legal Framework

November 10, 2019

Live tutorial materials: Follow the curriculum – Reading: For a useful comparative tool on TP country-by-country, look at: https://www.lexology.com/navigator# and select the topic “transfer pricing” Victor Thuronyi Comparative Tax Law – this is a GREAT general book on International Tax as the legal framework applicable to TP, especially: 1.3 Legal Families, page 31 4.1 Tax Law and part of […]

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

TP Lecture week 1 – TP Legal Framework

November 10, 2019

General background summary reading for a FULL overview of TP, in this order, which should be your ongoing reading during this course: 6 Chapter Transfer Pricing B Arnold International Tax Primer 3rd ed An Overview of Transfer Pricing by IBFD PWC International TP 2015-16 up to page 182 Follow the curriculum – Reading for the lecture: OECD […]

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

OECD secretariat invites public input on the Global Anti-Base Erosion (GloBE) Proposal under Pillar Two

November 8, 2019

In May 2019, the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework) agreed a Programme of Work for Addressing the Tax Challenges of the Digitalisation of the Economy. The Programme of Work is divided into two pillars: Pillar One addresses the allocation of taxing rights between jurisdictions and considers various proposals for new profit allocation and nexus rules; Pillar […]

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BEPS requirements on CbC Reporting – Background reading

November 6, 2019

Please see the following document as background reading: http://www.oecd.org/tax/beps/country-by-country-reporting-handbook-on-effective-tax-risk-assessment.pdf

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