Recent TP Cases

November 6, 2019

TP Judgments in Africa 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 summary of the above case – Crookes Bros case […]

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S.Africa: Recent cases relevant to tax issues – summarised

November 5, 2019

Public Protector v South African Reserve Bank (CCT107/18) [2019] ZACC 29; 2019 (9) BCLR 1113 (CC) (22 July 2019) The issues were whether: (a) the test of gross negligence or bad faith was relied on; (b) the legal requirements for awarding personal costs against a representative litigant were met; (c) correct legal principles for awarding costs […]

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S.Arica updates: Foreign Employment Income Exemption & SARS issues updated list of jurisdictions contemplated in CbC regulations

October 31, 2019

South Africa Report from our correspondent Lutando Mvovo, South Africa Foreign Employment Income Exemption; Frequently Asked Questions (FAQs) (Issue 2)On 22 October 2019, the South African Revenue Service (SARS) published frequently asked questions (Issue 2) on the foreign employment income exemption. The FAQs are drafted to assist employees, employers and the public to obtain clarity and to […]

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TP Minds conference in Johannesburg: TP case update by Prof. Dr. Daniel N. Erasmus

October 31, 2019

Below is a link to the short presentation on the latest Africa TP cases and the experience of Dr. Erasmus arguing tax cases in various African jurisdictions. He also shares the techniques on how to avoid tax litigation: https://www.dropbox.com/s/6uosb1j07goq0ws/TP%20Minds.mp4?dl=0

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TP judgments in Africa – as at Nov 2019

October 30, 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 related 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

Africa Brief 28 Oct 2019

October 29, 2019

Africa Doing Business 2020: Two sub-Saharan African countries among most improved in Ease of Doing Business Economies in sub-Saharan Africa continued to improve their business climates, with the region’s largest economy, Nigeria, earning a place among the year’s top global improvers alongside Togo, according to the World Bank Group’s Doing Business study. Economies of the […]

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UN: Practical Manual on Transfer Pricing

October 28, 2019

As the OECD ventures forth in digital transactions and global minimum tax standards, it is always helpful to keep in  mind the UN Practical TP Manual for Developing Countries, which adheres to the arm’s-length principle.  Links to the Manual and the Committee of Experts on International Cooperation in Tax Matters are provided for reference. In […]

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Africa tax in brief

October 24, 2019

22 OCT 2019 ENSafrica – Celia Becker ANGOLA: Treaty with Portugal enters into force On 22 August 2019, the Angola-Portugal Income Tax Treaty (2018) entered into force and generally applies from 1 January 2020. ANGOLA: New VAT Law enters into force On 1 October 2019 the VAT Law came into effect, replacing the Consumption Tax […]

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Combatting Tax Crimes More Effectively in APEC Economies

October 15, 2019

Tax evasion and related financial crime threaten the strategic, political, and economic interests of all countries. Recognising the threat that such illicit financial flows pose to the Asia-Pacific region, APEC Finance Ministers developed the Cebu Action Plan, a roadmap for a more sustainable financial future, calling on all APEC Economies to build their capacity to address […]

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Exchange of information: disputes multiply

October 14, 2019

Jonathan Schwarz (Temple Tax Chambers; King’s College London)/October 14, 2019  Some four years ago in this blog, I wrote about problems that would start to emerge as exchange of information between tax administrations became more routine and extensive.  If nothing else, the number of disputes in this area was bound to increase. See also Exchange of Information: bumps in […]

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