ATL-Editor

The Inland Revenue document Multinational Enterprises Compliance Focus (2019) focuses on the base erosion and profit shifting (BEPS) measures implemented since the previous version of the document (2016) was released, and explains how compliance with these measures will be monitored and enforced to determine that MNEs pay their “fair share” of New Zealand tax. Overview of Inland […]

In May 2019, the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework) agreed a Programme of Work for Addressing the Tax Challenges of the Digitalisation of the Economy. The Programme of Work is divided into two pillars: Pillar One addresses the allocation of taxing rights between jurisdictions and considers various proposals for new profit allocation and nexus rules; Pillar

Please see the following document as background reading: http://www.oecd.org/tax/beps/country-by-country-reporting-handbook-on-effective-tax-risk-assessment.pdf

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

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

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

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{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Minds.mp4?dl=0