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

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

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

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

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

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

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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Recent TP Cases

TP Judgments in Africa The first Ghana TP  case – TP Ghana JUDGMENT IN TAX APPEAL CASE BETWEEN BIERSDORF GH LTD AND THE COMM GENERA… The first RSA TP case – Crookes Brothers Ltd v Commissioner for the South African Revenue Service [2018] ZAGPHC 311 (judgment delivered 8 May 2018) This is  a summary of the above case – Crookes Bros case […]

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S.Africa: Recent cases relevant to tax issues – summarised

Public Protector v South African Reserve Bank (CCT107/18) [2019] ZACC 29; 2019 (9) BCLR 1113 (CC) (22 July 2019) The issues were whether: (a) the test of gross negligence or bad faith was relied on; (b) the legal requirements for awarding personal costs against a representative litigant were met; (c) correct legal principles for awarding costs […]

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S.Arica updates: Foreign Employment Income Exemption & SARS issues updated list of jurisdictions contemplated in CbC regulations

South Africa Report from our correspondent Lutando Mvovo, South Africa Foreign Employment Income Exemption; Frequently Asked Questions (FAQs) (Issue 2)On 22 October 2019, the South African Revenue Service (SARS) published frequently asked questions (Issue 2) on the foreign employment income exemption. The FAQs are drafted to assist employees, employers and the public to obtain clarity and to […]

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TP Minds conference in Johannesburg: TP case update by Prof. Dr. Daniel N. Erasmus

Below is a link to the short presentation on the latest Africa TP cases and the experience of Dr. Erasmus arguing tax cases in various African jurisdictions. He also shares the techniques on how to avoid tax litigation: https://www.dropbox.com/s/6uosb1j07goq0ws/TP%20Minds.mp4?dl=0

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