Paper by: Olamide Akinla Nigeria introduced Transfer Pricing Regulations in August 2012. One of the innovations of the Regulations is the introduction of Advance Pricing Agreements (APAs). This discourse would, inter alia, examine what an APA is, the types of APAs, their relevance to both taxpayers and tax administrations, the provisions of the Nigerian Transfer […]
THE UTILITY OF ADVANCE PRICING AGREEMENTS (APAs) Read More »
This annual publication presents a unique set of detailed and internationally comparable tax data in a common format for all OECD countries from 1965 onwards.Available: 5 December 2019 We will make it available on 5 December 2019.
OECD – Revenue Statistics 2019 Read More »
In a world that is moving at a fast pace in the light of the “disruptive” digitalization processes happening at the moment, it is essential for taxpayers to be aware of their rights and of the balance of power existing between them and the tax authorities (“TAs”). In this webinar we will discuss rulings from the
Tax Controversy – Impact Of ‘Disruptive’ Digitalization Processes on Taxpayers Read More »
The Tax Appeal Tribunal, Lagos Zone (“TAT” or the “Tribunal”), recently held thatservices which flow from service providers in Nigeria to third parties (such as, persons resident in Nigeria) on behalf of or for the benefit of persons resident outside Nigeria do not constitute exported service for tax purposes in Nigeria. It also held that
International tax law principles deal with the allocation to various jurisdictions of taxing rights in respect of the business profits of a multi-national company. The basic idea is that the country of residence of a company (ie whether a company is incorporated or where its board of directors make their decisions) can tax all the
SOUTH AFRICA – Tax revenues from the digital economy – Peter Dachs (ENSAfrica) Read More »
DTC are binding agreements between usually two States and thus are governed by Public International Law. In the majority of jurisdictions, the introduction of DTC into domestic legislation is required for having binding effects. Paraguay follows this legal principle, where ratified treaties are above national law – but below the Constitution – upon exchange of
The one that should have to be in the problem is the one that is included in the spectrum of being good to those around him that the person goes in the way that will ultimately contribute to the on that enhance to the best of the person that will entitled to those that are
A critical analysis of the relevance of the OECD Model article 17 in Double Tax Agreements from a South African perspective and the misalignment of this article in South African DTAs (in force at 1 June 2008) when compared against the final withholding tax on the gross earnings of nonresident sportspersons performing in South Africa…
Recently, we have been asked to consider an often overlooked VAT exposure, namely, the potential taxable supplies involved in low or nil cost intra-group financing and security transactions. Everyday intra-group financing arrangements such as, for example, provision of interest free loans, and the provision of intra-group guarantees, suretyships and/or subordination agreements, may constitute the supply
