Archive | April, 2018

International Tax: When Countries go Rogue – a summary article

VERSION 1 – Summary: Tax Planning International Article on “Taxpayers Going Rogue, summarized article by Cecilia Stassen With multinational entities and digital companies becoming an everyday occurance and the status quo of doing business, governments are concerned with the shifting of profits away from the jurisdiction in which the entities mainly operate. In light of the […]

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

International Tax Update May 2018 – Prof Dr Daniel N Erasmus will be in attendance

  Trends in International Taxation: An African Perspective Why attend? IBFD’s Africa Tax Symposium is an excellent opportunity to increase your knowledge and strengthen your network. This year’s programme will focus on the most challenging tax issues of today, such as the impact of the Multilateral Instrument on bilateral tax treaties, challenges of the digital […]

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

IT Lecture week 24 – International Tax Structuring

This lecture will most likely be given by a guest lecturer who specializes in international tax structuring. The reading requirements are: 14 16 2018 Anti ­abuse legislation The Importance of Substance in a Private Equity Fund Context 14 16 anti-avoidance how robust is a Structured Finance Deal Read the double-dip leasing example in Chapter 1.4 of your Primer again – 1 Chapter Introduction on page 11 1 […]

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

Transfer Pricing course contents table of reading materials by lecture

TRANSFER PRICING COURSE – Lectures, tutorials, assignments – reading materials  General ongoing reading as the courses advance: 1. reading about 10 pages a week to gain an overview understanding:https://www.africataxjournal.com/wp-content/uploads/2018/04/An-Overview-of-Transfer-Pricing-by-IBFD.pdf 2. 6 Chapter Transfer Pricing B Arnold International Tax Primer 3rd ed 3. PWC International TP 2015-16: Part 1: Developing defensible transfer pricing policies Introduction……………………………………3 Categories of inter-company transfer…..9 The work […]

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

International tax course contents table of reading materials by lecture AND curriculum

Course Curriculum: see https://www.africataxjournal.com/?p=1327   INTERNATIONAL TAX COURSE lectures, tutorials & assignments reading by each week: New IT Course Web Addresses Index        

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

Transfer Pricing Course Assignment and Tutorial Questions

All the assignment dates and the tutorial dates for submission of answers can be found on the Curriculum Spreadsheet: see  https://www.africataxjournal.com/?p=1330 Any late assignments and tutorial answers submissions will NOT be marked. You will lose your points/marks.   ASSIGNMENTS The 3 assignments counts 10% each, ie. 30% towards the 100% course marks/points: Assignment 1 TP one source study assignment Here are the 2018 […]

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

International Tax Course Assignment and Tutorial Questions

All the assignment dates and the tutorial dates for submission of answers can be found on the Curriculum Spreadsheet: see https://www.africataxjournal.com/?p=1327 Any late assignments and tutorial answers submissions will NOT be marked. You will lose your points/marks.   ASSIGNMENTS The 3 assignments counts 10% each, ie. 30% towards the 100% course marks/points: Assignments 2018 vr2 – 3 assignments. […]

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

IT Lecture weeks 22 and 23 – Emerging issues

Follow curriculum – Reading: International Tax Primer 3rd Edition Brian Arnold – eBook – Chapter 9 http://www.oecd.org/ctp/beps-2015-final-reports.htm – Action 1 – Digital economy; Action 2 – Hybrid mismatches; Action 5 – Harmful business practices; Action 14 – Dispute resolution   Additional supplementary reading – some required to answer tutorial questions: 22 23 2018 SARS’s stance on the tax […]

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

IT Lecture weeks 17, 18, 19, 20 and 21 – Tax Treaties

Follow curriculum – Reading: International Tax Primer 3rd Edition Brian Arnold – eBook – Chapter 8 OECD Income and Capital Model Convention and Commentary 2017 ARTICLES 1 to 4; 5 and 7; 6, 13 and 22; 11 and 12; 24; and 27; and commentaries UN Model Double Taxation Convention and Commentaries 2011 Update ARTICLES 1 to 4; 5 […]

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

IT Lecture weeks 14, 15 and 16 – Other anti-avoidance measures

Pre-recorded lectures on anti-avoidance and CFC provisions using S.Africa as a practical example: Lecture 14 Anti-avoidance LECTURE: https://www.dropbox.com/s/m1hzmk3ojko3h6f/Week%2014_DrErasmus.mp4?dl=0 – please note that you were required to listen to this lecture to answer Tutorial question 97. If you have done so, please do the additional reading below, and only then move onto the CFC lecture. If you have […]

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