Archive | May, 2018

SARS’ new DRAFT Mutual Agreement Procedure

SARS MAP Guide DRAFT 2018 Draft Guide on MAPs CONTENTS Preface…………………………………………………………………………………………………………………ii Glossary ………………………………………………………………………………………………………………1 1. Background ……………………………………………………………………………………………….1 1.1 What is a mutual agreement procedure?………………………………………………………………………..2 1.2 Legal basis for mutual agreement procedure ………………………………………………………………….5 1.3 Multilateral Instrument………………………………………………………………………………………………….6 1.4 The role of a competent authority ………………………………………………………………………………….7 1.5 South Africa mutual agreement procedure profile and website………………………………………….7 2. In what instances […]

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

Blockchain links to research and understanding more on potential international tax issues

More on blockchain and the cryptocurrency – Ethereum Well to quote Blockgeeks: Every single operation that takes part in Ethereum, be it a simple transaction, or a smart contract, or even an ICO takes some amount of gas. Gas is what is used to calculate the amount of fees that need to be paid to […]

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

How blockchain will assist advisors to become more strategic in their advisory roles

Many have observed that technology will free up time for lawyers to engage in more strategic and higher value activities. To be better problem-solvers, more commercial and more creative. What do these concepts mean? What kinds of skills are involved?You often hear clients describe a good lawyer as someone who is commercial, practical, creative, strategic, etc. But […]

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

Digital economy and taxation presentation at the IFA Tax Conference in Mauritius

AI Robotics the future taxes – A US perspective-2 Why the OECD investigation direction on the digital economy and taxation may fail, because they do not clearly understand  what is happening with the current blockchain technological revolution. By Prof. Dr. Daniel N. Erasmus daniel@taxriskmanagement.com www.TaxRiskManagement.com

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

South Africa – Cryptocurrency – I believe SARS is wrong in part of their analysis

My view – where cryptocurrency is held as a currency to buy goods or services, when its value is released on buying those goods or services as a currency, there should be no tax consequence.  Just like when you hold dollars, that are converted to Rands when you buy goods and services. You are not […]

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

Amsterdam – Global Tax Controversy – Workshop for Corporates – 21 June 2018

The brochure: TPA Global Tax Controversy – Workshop for Corporates Some large corporations are in attendance in personalized small workshops. You are invited to attend. http://www.tpa-global.ccom/gtc2018  

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

Advanced Diploma – Transfer Pricing Curriculum and reading materials

Curriculum – AD Transfer Pricing 2018 vr6 Please note that the tutorial questions and the assignments are embedded in the Curriculum Spreadsheet with hyperlinks to make it easier to prepare. But the essential reading materials are set out below, with addition up-to-date reading you should be doing as changes are made by the OECD and other […]

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

Advanced Diploma – International Tax Curriculum and reading materials

Curriculum – New Curriculum vr5 Please note that the tutorial questions and the assignments are embedded in the Curriculum Spreadsheet. Reading materials per lecture – https://www.africataxjournal.com/?p=1040 Prescribed reading materials: International Tax Primer 3rd Edition Brian Arnold – eBook Victor Thuronyi Comparative Tax Law Basic International Taxation Vol I by Roy Rohatgi – eBook UN Model Double Taxation Convention […]

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ABA International Africa Section – Challenging Risk Perception in Africa – tax is the biggest business risk in Africa

Why is tax one of the biggest business risks in Africa, that interlinks with corruption? Corrupt officials and governments use the desperately needed tax funds for social uplifting and development in a corrupt manner. This places more pressure on the fiscus to collect more taxes. MNEs then start facing ambitious, but often wrong tax assessments […]

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Mauritius IFA moot court judgment on a TP related procedural issue

The facts are set out here: Facts The moot judgment: Disputes Mauritius Legit Expect judgment The supporting documents: TP SARS Practice Note 7 Income Tax Practice Note 7 of 1999 SARS arguments Legitimate Expectation note OECD How Acquiescence and Estoppel legally bound to OECD commentaries by Frank Engelen Unilever Kenya Ltd v Commissioner KRA Income […]

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