Africa is being left out of the digital tax loop – by Daily Maverick

April 12, 2019

Google parent company Alphabet reported recently its full-year results for 2018, announcing income of $30-billion off a revenue of $137-billion. But the eye-popping thing about the earnings statement was that its tax bill was just $4.2-billion, 12% of its pre-tax income, which was less than the $5-billion it paid in fines to the European Union. […]

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Ghana: Pay some tax before filing tax appeal

April 11, 2019

GHANA: High Court rules that payment of minimum disputed amount is a prerequisite for filing an appeal The Commercial Division of the High Court, in its decision of 13 July 2018, in the case of Beiersdorf Ghana Limited v. The Commissioner General of the Ghana Revenue Authority (CM/TAX/0001/2018), ruled that the payment of at least […]

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S.Africa: Country by Country reporting

April 11, 2019

Country-by-Country Reporting and Transfer Pricing SARS issued a public notice on 20 October 2017 which stipulates the requirements and timeframes for Country-by-Country Reporting (“CbCr”) and transfer pricing documentation (master file and local file).  The requirements for CbCr which apply for financial years commencing on or after 1 January 2016 is a consolidated Multi-National Entities (“MNE”) group turnover […]

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TP Zambia: Nestle Zambia Trading Ltd v MRA

April 1, 2019

https://www.africataxjournal.com/wp-content/uploads/2019/04/Nestle-vs-ZRA-TP-Case-2019.pdf

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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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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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