Archive | West Africa

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

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

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: […]

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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 […]

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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) […]

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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 […]

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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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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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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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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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