Archive | FP News

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

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

Read the full story

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

S.Africa: 20 February 2019 Budget – tax proposals

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

Read the full story

Posted in FP News

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

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 […]

Read the full story

Posted in FP News

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

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: […]

Read the full story

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

TRANSFER PRICING BUSINESS MODELS

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 […]

Read the full story

Posted in FP News

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

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 […]

Read the full story

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

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

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 […]

Read the full story

Posted in FP News

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

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) […]

Read the full story

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

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

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 […]

Read the full story

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

S.Africa: Revenue Service issues interpretation note on headquarter companies

South Africa Report from our correspondent Lutando Mvovo, South Africa Revenue Service issues interpretation note on headquarter companies On 28 November 2018, the South African Revenue Service (SARS) published Interpretation Note 87 (Issue 2) (IN 87) on headquarter companies. The purpose of IN 87 is to provide guidance and clarity on the interpretation and application […]

Read the full story

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