Archive | 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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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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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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More than one way to skin a cat? High Court considers SARS’ power to issue reduced assessments

by Cliffe Dekker Hofmeyr  Introduction Under Section 93 of the Tax Administration Act (28/2011), there are five circumstances under which the South African Revenue Service (SARS) may issue a reduced assessment in order to reduce a person’s tax liability. While Section 93 makes it possible to ‘skin a cat’ (ie, reduce tax liability) in more […]

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The Tax Ombud’s Report is in and the results are few. Is the office of the Tax Ombud doing its job?

The Tax Ombud’s Report is in and the results are few. Is the office of the Tax Ombud doing its job? Cliffe Dekker Hofmeyr South Africa October 19 2018 What is the Tax Ombud supposed to do? Following the lead of international best practices, the South African OTO is modelled on the Tax Ombud systems of […]

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