Malawi: Tax issues – TREASURY FAULTED ON INVESTOR TAX BURDEN

June 26, 2019

STEVE CHILUNDU Staff Reporter Economists and tax experts have faulted Treasury for introducing tax policies that are not favourable in attracting Foreign Direct Investment (FDI) in the country. However, Treasury downplayed the assertions that the country is worse off in terms of its taxation regime saying there are a lot of specific incentives offered to […]

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Digest of Important Judgments on Transfer Pricing and International tax – 2018

June 22, 2019

http://www.fitindia.org/downloads/digest_of_1350_it_and_tp_cases_2018.pdf The Digest contains 1350 important judgments which were pronounced by Courts and Tribunals in the period from January 2018 to December 2018. o Of these, there are 1150 judgments on Transfer Pricing and 200 judgments on International Taxation. o The author/ Trustee has meticulously and systematically classified the judgments into various categories to enable […]

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ZIMBABWE: Income tax (transfer pricing documentation) regulations 2019 issued

June 20, 2019

The Minister of Finance and Economic Development issued the Income Tax (Transfer Pricing Documentation) Regulations 2019 by Statutory Instrument 109 of 2019 on 10 May 2019. The regulations became effective on the same date and detail documentation to be submitted (in English) within seven days from the date of a written request by the commissioner. […]

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Mauritius 2019 Budget Speech

June 11, 2019

The Prime Minister of Mauritius presented the Mauritian Budget Speech for the 2019/20 year yesterday. The important tax proposals, insofar as they are relevant for South African tax residents looking to use Mauritius as a jurisdiction for tax planning, may be summarized as follows- An amendment to the definition of the tax residency of companies whereby any Mauritian incorporated […]

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Tax risk management free pdf book

June 11, 2019

  by Dr Daniel N Erasmus PhD EA USTCP Int’l Tax Attorney   Tax Risk Management is more relevant than ever. Here is a tax risk management plan template, based on our one project in Hungary for a MNE: TRM Policy Document PRECEDENT General with Hungary – case study Here is a groundbreaking judgment against […]

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

TP articles in DTAs being used as “tax charging sections”

June 9, 2019

Here are the recent cases where the courts have considered whether or not Article 9 Associated Enterprise or it’s equivalent can be used as a “charging section” for TP in domestic legislation: It should be noted that some countries like Australia and France have domestic tax provisions that entitle them to use Article 9 as […]

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TP: A short course in drafting TP related Agreements

May 29, 2019

Not only is theory important on TP. But how does this translate into practice. Here is a useful short course on drafting TP related agreements: www.IITF.net is currently designing a similar course as a follow up to the Post Graduate Diploma TP course offered through Middlesex University.

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UN TPGs

May 29, 2019

Here are the latest UN TPGs: https://www.africataxjournal.com/wp-content/uploads/2018/04/11-13-UN-Practical-Manual-on-Transfer-Pricing-for-Developing-Countries-2017.pdf

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Supporting documents to the TP Introduction and Update Seminar

May 27, 2019

The Continuing Education Questions are at the bottom of this page. Seminar recordings: Lecture 1 – https://www.dropbox.com/s/qhufher4kxqchxb/1st%202018-07-25%2014.30%20Transfer%20Pricing%20-%20Introduction%20Course%20by%20Dr%20Daniel%20Erasmus.mp4?dl=0 The first part of the first lecture by Prof. Dr. Erasmus was not clear due to connectivity issues. That first part is clearly recorded above. alternate link: https://www.dropbox.com/s/0ucej5b6kjhicp8/2018-07-25%2014.30%20Transfer%20Pricing%20-%20Introduction%20Course%20by%20Dr%20Daniel%20Erasmus.wmv?dl=0 Lecture 2 – https://www.dropbox.com/s/5jsd2z3dmqkilat/2nd%202018-07-26%2014.31%20Transfer%20Pricing%20-%20Introduction%20Course%20by%20Dr%20Daniel%20Erasmus.mp4?dl=0 alternate link: https://www.dropbox.com/s/xeqj6udkgep8r7t/2018-07-26%2014.31%20Transfer%20Pricing%20-%20Introduction%20Course%20by%20Dr%20Daniel%20Erasmus.mp4?dl=0 Lecture 3 – https://www.dropbox.com/s/bv4uj60idtj1nlo/3rd%202018-07-27%2014.30%20Transfer%20Pricing%20-%20Introduction%20Course%20by%20Dr%20Daniel%20Erasmus.mp4?dl=0 alternate link: https://www.dropbox.com/s/5fib6anelg6241w/2018-07-27%2014.31%20Transfer%20Pricing%20-%20Introduction%20Course%20by%20Dr%20Daniel%20Erasmus.mp4?dl=0 Updated and […]

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

KENYA: High Court ruling on Mauritius treaty

May 22, 2019

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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