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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 […]

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

S.Africa: New VAT regulations for electronic services effective April 2019

New VAT regulations for electronic services effective April 2019 Baker McKenzie – Stephan Spamer and Seelan Moonsamy South Africa November 26 2018 The National Treasury recently published an amended Regulation for electronic services, in line with the proposal by the Minister of Finance in Budget Review 2017, that the value added tax (VAT) base for electronic services was to be […]

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

S.Africa: Important judgment on simulation handed down by Supreme Court of Appeal

Important judgment on simulation handed down by Supreme Court of Appeal On 9 November 2018, the South African Supreme Court Appeal (“SCA”) handed down an important judgment in which it upheld Sasol Oil (Pty) Ltd’s appeal against a judgment of the Gauteng Tax Court. The facts of the case were complex, but concerned certain back-to-back […]

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

South Africa’s Revenue Service releases updated guidance on seeking mutual agreement procedure assistance

South Africa’s Revenue Service releases updated guidance on seeking mutual agreement procedure assistance DLA Piper South Africa’s Revenue Service (SARS) has issued an updated guide on Mutual Agreement Procedures (Issue 2) for taxpayers. The Guide contains general information on the background to the mutual agreement procedure (MAP), the use of MAP in general, and specific […]

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US: Medtronic TP case – 8th Circuit Court

TPA tech meeting medtronic case The full appeal case is here: US TP Medtronic case 2018 In this edition: the U.S. Court of Appeals for the Eighth Circuit remands the Medtronic case back to the Tax Court for comparability analysis; the U.S. Tax Court found in favor of Illinois Tool Works Inc. in an intercompany […]

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

S.Africa: New electronic services regulations: Widening the invisible VAT net

New electronic services regulations: Widening the invisible VAT net Cliffe Dekker Hofmeyr Foreign suppliers of e-services are required to register for VAT in South Africa if at least two of the following circumstances are present: the recipient of the services is a South African resident; the payment for services originates from a South African bank […]

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S.Africa – Win for mining industry: High Court rules on calculation of royalties

In the recently decided United Manganese of Kalahari (Proprietary) Limited v Commissioner for the South African Revenue Service,(1) United Manganese of Kalahari (Proprietary) Limited (UMK) applied to the Gauteng Provincial Division, Pretoria (High Court) for declaratory relief in relation to the correct interpretation and application of Section 6(3)(b) of the Mineral and Petroleum Resources Royalty Act (28/2008) […]

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S.Africa – SARS Share Owners Tax Guide

SARS 2018 Tax Guide for Share Owners Revenue Service issues tax guide for share owners On 5 November 2018, the South African Revenue Service (SARS) published the Tax Guide for Share Owners (Issue 6). The Guide summarizes the key aspects that holders of shares need to be aware of in computing their liability for income […]

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

Revenue statistics in Africa – 3rd edition

The third edition of Revenue Statistics in Africa, released today in Paris during the 18th International Economic Forum on Africa, shows that tax-to-GDP ratios varied widely across African countries, ranging from 7.6% in the Democratic Republic of the Congo to 29.4% in Tunisia in 2016. Six countries -Mauritius, Morocco, Senegal, South Africa, Togo and Tunisia- […]

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South Africa: Country-by-country CBC guide by SARS – creating confusion?

Look at the following Guide on CBC by SARS at page 23: SARS 2018 cbc – How to complete and submit your Country by Country information – External Guide Here SARS suggests you include dividends. This should not be read as increasing the R100m MNE threshold for “affected transactions” unless those dividends are linked to […]

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