Archive | January, 2018

US Tax Reform 2018 – GILTI and “deemed transition tax” for US taxpayer individuals and pass-through LLCs

US 2018 Tax Reform Bill H.R.1 sections 14201 and 14202 on GILTI US 2018 Tax Reform us-tax-reform-context-new-tax-concepts-and-impact-on-your-business-models A US taxpayer, if you own shares in a foreign company of more than 10% – major repercussions are in play now after the latest US tax reform amendments Published on February 1, 2018 Dr Daniel N Erasmus […]

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How To Deal With PE Risks In Practice post BEPs? – A 5-step Approach

How To Deal With PE Risks In Practice Post BEPS? – A 5-step Approach In an attempt to close the loopholes of the existing PE definition through BEPS Action 7, the OECD has, inadvertently, also lowered the threshold for the classification of the local business activities of a foreign enterprise as a PE of such […]

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OECD TPG 2017

OECD TPG Transfer Pricing Guidelines for Multinational Enterprises and Tax Administration July 2017

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OECD TPG 2010

OECD TPG TRANSFER PRICING GUIDELINES 2010

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TP and Mining in Africa – A Reference Guide for Practitioners

TP Transfer pricing in mining-with-a-focus-on-Africa-a-reference-guide-for-practitioners-Web

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