ATL-Editor

South Africa – a snapshot of the latest tax developments in South Africa by ENS

Tax Court of South Africa, Cape Town | CM v CSARS (TAdm 0035/2019) the Applicant sought default judgment against SARS in terms of Rule 56 of the Tax Court Rules to reduce her tax liability to nil, where she alleged that SARS was in default of its obligation to file a Rule 31 statement (i.e.

South Africa – a snapshot of the latest tax developments in South Africa by ENS Read More »

AN ANALYSIS OF CHALLENGING THE COMMISSIONER’S DISCRETIONARY POWERS INVOKED to Audit in terms OF THE INCOME TAX ACT 58 OF 1962, IN LIGHT OF THE CONSTITUTION OF THE REPUBLIC OF SOUTH AFRICA 108 OF 1996

https://www.academia.edu/s/fc609c8e64?source=link The PH.D. thesis is equally applicable to the new Tax Administration Act, 2011.

AN ANALYSIS OF CHALLENGING THE COMMISSIONER’S DISCRETIONARY POWERS INVOKED to Audit in terms OF THE INCOME TAX ACT 58 OF 1962, IN LIGHT OF THE CONSTITUTION OF THE REPUBLIC OF SOUTH AFRICA 108 OF 1996 Read More »

Postgraduate Diploma in International Taxation Course Start Date: 31st March 2020

Brand new course to help grow your international taxation career in 2020… Postgraduate Diploma in International TaxationCourse Start Date: 31st March 2020Tutored Distance LearningCreated and delivered by the IITF Convenor: Prof. Dr. Daniel N. Erasmus Gain a firm grounding on all must-know International Taxation areas with our brand new Postgraduate Diploma in International Taxation. This distance learning

Postgraduate Diploma in International Taxation Course Start Date: 31st March 2020 Read More »

The Inclusive Framework is considering radical proposals, but in the real world… – Ben Dickinson

In her recent blog, Allison Christians usefully alerts us to some of the challenges and opportunities of the new rules on international taxation being negotiated at the OECD. However, it is important to shed some additional light on the dynamics and context of the Inclusive Frameworkprocess. The acute tensions we see in the international tax system have indeed

The Inclusive Framework is considering radical proposals, but in the real world… – Ben Dickinson Read More »

OECD Invites Taxpayer Input On Tenth Batches Of Dispute Resolution Peer Reviews

The OECD is now gathering input for the Stage 1 peer reviews of Andorra, Aruba, Bahrain, Barbados, Gibraltar, Greenland, Kazakhstan, Oman, Qatar, Saint Kitts and Nevis, Thailand, Trinidad and Tobago, United Arab Emirates and Viet Nam, and invites taxpayers to submit input on specific MAP-related issues by 16 December 2019. Current request for input: Type

OECD Invites Taxpayer Input On Tenth Batches Of Dispute Resolution Peer Reviews Read More »

USA – The Attorney-Client Privilege Does Not Protect Client Identities – Richard A. Nessler (Winston & Strawn LLP)

In Taylor Lohmeyer Law Firm PLLC v. United States,1 the Taylor Lohmeyer Law Firm (the “Firm”) unsuccessfully challenged a John Doe summons issued by the IRS, which sought to attain the names of the Firm’s clients. On May 15, 2019, the Western District of Texas rejected the Firm’s petition to quash the summons, instead granting the Government’s

USA – The Attorney-Client Privilege Does Not Protect Client Identities – Richard A. Nessler (Winston & Strawn LLP) Read More »

The DAC6 Intermediary: multiplying compliance-costs and creating loopholes – Martijn Weijers (Pelinck Nijssen Weijers)

In June 2017, the European Commission published its proposal on transparency rules for tax planning by intermediaries and certain taxpayers (the Commission proposal). The Commission proposal was amended multiple times, before it was formally adopted as Directive 2018/822 (DAC6) on 25 May 2018. DAC6 requires Member States to put in place, by 31 December 2019,

The DAC6 Intermediary: multiplying compliance-costs and creating loopholes – Martijn Weijers (Pelinck Nijssen Weijers) Read More »