Archive | June, 2018

Various Constitutions and why they are important in tax

SOURCE: of Constitutions of various Countries http://www.wipo.int/wipolex/en/ The above link not only introduces you to various treaties and laws per country on IP issues (relevant to transfer pricing issues), but also gives you access to the latest Constitutions. In tax law, Constitutions are important to establish if: – the Constitution is the Supreme Law and […]

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

Update on the Tax Dispute Resolution Process – 26 June 2018

This online seminar is presented by Prof. Dr. Daniel N. Erasmus and Schalk Pieterse, both experienced practitioners in this field. The 2 have worked together on numerous cases where Erasmus has been  instructed by Pieterse to argue the tax dispute matters in court as Counsel. Here are the PPT presentation slides: DISPUTE RESOLUTION WEBINAR 26 […]

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

South Africa: Controlled Foreign Companies (CFC’s)

By ENS Section 9D of the Income Tax Act, 1962 (the “Act”) is aimed at South African residents who directly or indirectly hold more than 50% of the total participation (broadly speaking shares) or voting rights in a foreign company. A foreign company in this context is classified as a controlled foreign company (“CFC”). In […]

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

The OECD released two reports containing Guidance for Tax Administrations on the Application of the Approach to Hard-to-Value Intangibles, under BEPS Action 8; and Revised Guidance on the Application of the Transactional Profit Split Method, under BEPS Action 10

The OECD released two reports containing Guidance for Tax Administrations on the Application of the Approach to Hard-to-Value Intangibles, under BEPS Action 8; and Revised Guidance on the Application of the Transactional Profit Split Method, under BEPS Action 10. In October 2015, as part of the final BEPS package, the OECD/G20 published the report on Aligning Transfer […]

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

South Africa – Reducing the cost of transfer pricing compliance for MNEs

Many countries have become more focused on combating tax avoidance. As such, transfer pricing compliance has become much more burdensome due to substantial documentation requirements and multiple filing deadlines. Multinationals (“MNEs”) have to take action to control their transfer pricing risks, but the cost of doing so could substantially increase. Before base erosion and profit […]

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

The OECD and the African Tax Administration Forum (ATAF) signed a renewal of their Memorandum of Understanding (MoU) until June 2023

Today, the OECD and the African Tax Administration Forum (ATAF) signed a renewal of their Memorandum of Understanding (MoU) until June 2023, agreeing to continue to work together to improve tax systems in Africa. The MoU sets their co-operation towards the achievement of the common objective of promoting fair and efficient tax systems and administrations […]

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

Supreme Court of Appeal upholds High Court ruling setting aside unlawful rates regime

Recently, the Supreme Court of Appeal (“SCA”) upheld a ruling handed down by the High Court in Pretoria 2 years ago, setting aside an exorbitant rates regime implemented by the City of Tshwane Metropolitan Municipality. The unlawful property rates regime arose following the amalgamation of the former Kungwini Municipality into the City of Tshwane. When […]

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