ATL-Editor

TP judgments in Africa – as at Nov 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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Africa Brief 28 Oct 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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Africa tax in brief

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

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

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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OECD Consulting on Digital Tax

The OECD published for stakeholders’ comments a proposal to advance international negotiations to ensure that multinational enterprises (MNEs), including digital companies, pay tax wherever they have significant consumer-facing activities and where they generate profits. The proposal – Secretariat Proposal for a Unified Approach – would re-allocate some profits and corresponding taxing rights to countries and jurisdictions where

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NEW book: Transfer Pricing and Value Creation

Recently published:Petruzzi/TavaresTransfer Pricing and Value Creation, Linde-Verlag Dear Colleagues, The Institute for Austrian and International Tax Law, WU (Vienna University of Economics and Business), is pleased to inform you about our most recent publication:Petruzzi/Tavares (Eds.) Transfer Pricing and Value Creation Linde Verlag 2019. Series on International Tax Law, vol. nr. 116ISBN: 9783707341232 Value Creation and

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Pieterse TRM Erasmus INC win another tax matter against SARS

Pieterse TRM Erasmus Inc won another matter yesterday with SARS conceding defeat after the filing of a Rule 32 court response. SARS realised that their procedural steps were fatally flawed. They had provided very scant reasons ( a few words – “insufficient evidence”) on assessment. However, they also effectively conceded the merits of the matter

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