Archive | August, 2019

International tax news

Switzerland to exchange financial account information with 33 more countries for tax purposesAugust 15, 2019Davide Anghileri of the University of Lausanne discusses an August 14 decision of Switzerland’s Federal Council confirming that Switzerland will exchange financial account information with 33 more reviewed partner countries . . .  OECD releases “stage 2” reports on tax dispute […]

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Belgium applies “formal interpretation” when doing foreign management and control test

Belgium applies “formal interpretation” when doing foreign management and control test On 23 November 2017, the Brussels Court of Appeal has applied a very “formal interpretation” when doing the foreign management and control test. The facts were as follows: A Belgium Group has a holding company in Luxembourg (“LuxCo”). LuxCo does not have its own […]

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Nigeria: Court rules imported services VATable in Nigeria

NIGERIA: Court rules that imported services are taxable in Nigeria The Court of Appeal in the Lagos Judicial Division, in its decision on 24 June 2019 in the case of Vodacom Business Nigeria Limited (Vodacom) v. Federal Inland Revenue Service (FIRS) (CA/l/556/2018), ruled that the destination principle and reverse charge are implied in the VAT Act. In […]

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NEW certificate in tax dispute resolution

https://mailchi.mp/904928007711/certificate-in-tax-dispute-resolution-2020 Convenor: Dr Daniel N Erasmus, brings years of practical tax dispute experience to this course, designed to educate professionals how best to defend their tax clients against tax audits and in tax court. Lecturers: Attorney Schalk Pieterse of the specialist tax firm Pieterse TRM Erasmus with Eddie Sneller, former senior SARS official now in […]

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TP Minds conference in Johannesburg: 29/30 October

Conference: 29 & 30 October 2019Venue: Radisson Blu Hotel SandtonJohannesburg   VIEW LATEST AGENDA   The international tax landscape is constantly changing – are you up to date? To hear how this affects you, join 100 of your peers at Africa’s leading transfer pricing forum. We will be hosting Africa’s largest multinational corporations, tax authorities and leading policy makers to […]

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IBFD country updates

Country Surveys – these require an IBFD subscription Botswana by Jude Amos(Reviewed up to 14 June 2019)Corporate TaxationGeneral anti-avoidance rules amended.Transfer pricing rules introduced.Thin capitalization rule replaced by rule based on a percentage of EBITDA.Amendment to Transfer Duty Act proposed. Cabo Verde by Leendert Verschoor, Catarina Nunes, Dúnia Moniz Delgado(Reviewed up to 1 April 2019)Corporate TaxationCorporate income tax rate reduced from 25% to […]

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South Africa: Wingate-Pearse v Commissioner for the South African Revenue Service and others [2019] JOL 45120 (GJ)

Wingate-Pearse v Commissioner for the South African Revenue Service and others [2019] JOL 45120 (GJ) Name of Court: High Court of South Africa, Held at Johannesburg Date of decision: 17 July 2019 Case number: 29208/15 S. Africa: Judgment handed down by High Court against Martin Fraser Wingate-Pearse FACTS On 17 July 2019, the High Court […]

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