Archive | July, 2019

South Africa: Recent tax and administrative law

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The International Taxation of Autonomous Artificial Intelligence (AAI): Questions from Leopoldo Parada

Lucas de Lima Carvalho (Brazilian Institute for Tax Law (IBDT))/July 16, 2019 /Leave a comment This is the second article of a short series that explores the international taxation of income attributable to Autonomous Artificial Intelligence (AAI). The series is based on an article written by the author and published by Kluwer in INTERTAX, Volume 47, […]

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The Importance of the Marcopolo Cases for Understanding the Application of the Brazilian Transfer Pricing Rules

The Importance of the Marcopolo Cases for Understanding the Application of the Brazilian Transfer Pricing Rules Francisco Lisboa Moreira (Bocater Advogados) and Ana Paula Saunders (Vale S.A.)/July 10, 2019/Leave a comment Brazilian Transfer Pricing Rules have been in force since 1996. When introduced, the intent of the legislator was clearly the prevention of tax evasion through manipulation of prices, […]

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A tale of three DTA’s: South African Tax Court confirms that no dividends tax is payable on distributions to Dutch resident shareholders

By FASKEN, The Netherlands In terms of section 64E(1)(a) of the Income Tax Act 58 of 1962 (“the ITA”) dividends tax at a rate of 20% must be paid when a South African company declares and pays a dividend. The amount of the tax must be withheld by the company declaring and paying the dividend. […]

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