Archive | May, 2019

KENYA: High Court ruling on Mauritius treaty

By ENS Africa update – KENYA: High Court ruling on Mauritius treaty On 15 March 2019, The High Court of Kenya gave its decision in the case of Tax Justice Network Africa (TJN-A) v. Cabinet Secretary for the National Treasury, The Kenya Revenue Authority and The Attorney General (Petition No 494 of 2014) regarding the constitutionality of […]

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TP judgments in Africa – as at May 2019

Here is a list of  the current cases: The first Ghana TP  case – TP Ghana JUDGMENT IN TAX APPEAL CASE BETWEEN BIERSDORF GH LTD AND THE COMM GENERA… The first RSA TP case – Crookes Brothers Ltd v Commissioner for the South African Revenue Service [2018] ZAGPHC 311 (judgment delivered 8 May 2018) This is  a […]

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

Zimbabwe: Income tax (transfer pricing documentation) regulations 2019 – issued

Zimbabwe Report from our correspondent Gershem T. Pasi, Revenue and Business Consultant, Zimbabwe Income tax (transfer pricing documentation) regulations 2019 – issued On 10 May 2019, the Minister of Finance and Economic Development issued Income Tax (Transfer Pricing Documentation) Regulations 2019 (the regulations) by Statutory Instrument 109 of 2019. The regulations deal with matters relating […]

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The IFA MAURITIUS 13th ASIA/AFRICA CONFERENCE 2019

POEM Panel notes: https://www.africataxjournal.com/wp-content/uploads/2019/05/Poem-Panel-IFA-Mauritius-2019.pptx POEM notes: https://www.africataxjournal.com/wp-content/uploads/2019/05/§-14.42-Place-of-effective-management.pdf

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

India: Recent Transfer Pricing cases – over case 900 summaries

Application of Transfer Pricing provisions not against “non-discrimination” clause of DTAA; DCF valuation subsumes goodwill: In the existing case, the taxpayer entered into a Share Purchase Agreement (“SPA”) with its Associated Enterprise (“AE”). The taxpayer’s share valuation report was rejected by the Transfer Pricing Officer (“TPO”) during the course of assessment proceedings and an upward adjustment […]

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