ATL-Editor

UN recommends African States update fiscal laws…and Zambia abandons Sales Tax

 Africa Business in Brief – 7 OCT 2019ENSafricaThe United Nations urged all African countries to reform their fiscal laws in order to enhance their tax revenues from the Digital Economy… Zambia sales tax abandonedENSafrica The Zambian Minister of Finance in his 2020 Budget Speech of Friday, 27 September 2019, announced that the government is abandoning […]

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Byrnes’ Comments on the OECD’s “Unified Approach” to Allocation of Profits of Digital Business

BEPS, DIGITAL SERVICES TAX, DIGITALIZATION, OECD, PERMANENT ESTABLISHMENTS, TRANSFER PRICING William Byrnes (Texas A&M University Law)/October 10, 2019  In my International Taxation class tomorrow (October 10th) we are going to discuss the  OECD’s “Unified Approach” released a day earlier on October 9, 2019.  Given the keen interest generated by digital taxation and the allocation of profits/losses generated therefrom, I thought it of interest

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IRS Cryptocurrency guidelines

In 2014, the IRS issued Notice 2014-21, 2014-16 I.R.B. 938 (PDF), explaining that virtual currency is treated as property for Federal income tax purposes and providing examples of how longstanding tax principles applicable to transactions involving property apply to virtual currency.  The frequently asked questions (“FAQs”) below expand upon the examples provided in Notice 2014-21 and

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Financial fraud concerns that will impact tax fraud against corporates

There is a growing concern that accounting practices are bordering on rubber-stamping what could be classified as fraudulent activities. “Fraud” is widely defined as: “a person or thing intended to deceive others, typically by unjustifiably claiming or being credited with accomplishments or qualities.” AND “wrongful … deception intended to result in financial or personal gain…”[which

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OECD leading multilateral efforts to address tax challenges from digitalisation of the economy

Today the OECD Secretariat published a proposal to advance international negotiations to ensure large and highly profitable Multinational Enterprises, including digital companies, pay tax wherever they have significant consumer-facing activities and generate their profits. The new OECD proposal brings together common elements of three competing proposals from member countries, and is based on the work of the OECD/G20

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OECD Tax Talks dates and times

    Wednesday, 9 October 201914:00 – 15:00 (CEST)With a number of important recent and upcoming developments in the OECD’s international tax work, experts from the OECD’s Centre for Tax Policy and Administration give the latest tax update. REGISTER Related Documents: BEPS Webcast Series Source: OECD Previous webcasts: OECD Tax Talks #12 (June 2019) OECD Tax Talks #11 (January 2019) OECD

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Zimbabwe: High Court annuls intermediated money transfer tax law

Zimbabwe Report from Richard Rukundo, Associate, IBFD High Court annuls intermediated money transfer tax law On 18 September 2019, the High court of Zimbabwe scrapped the 2{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e} transaction tax which was introduced by the government through the Finance (Rate and Incidence of Intermediated Money Transfer Tax) Regulations, 2018 (The Regulations). The Regulations were introduced as

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S.Africa: Recent case summaries relevant to tax administrative principles

Karin Steenkamp and others v Edcon Limited, decided by Constitutional Court: This was a labour law matter where the Labour Appeal Court refused the applicants condonation for the late launching of an application in terms of the Labour Relations Act. The Judgment discusses the principles applicable to appeals against the grant or refusal of condonation

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Taxation of Space: the final frontier*

Jonathan Schwarz (Temple Tax Chambers; King’s College London)/September 27, 2019  While earthlings are grappling with taxation in a digitalised world, a new and important frontier has been opening up somewhat less observed. Commercial exploitation of space has become commonplace and plans for activity beyond our planet more ambitious. At the IFA Permanent Scientific Committee  we are always looking

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Some observations on Starbucks, Fiat, and their potential impact on future amendments to the arm’s length principle

Jérôme Monsenego (Stockholm University)/September 28, 2019 The General Court of the European Union has issued two awaited rulings in the Starbucks[1] and Fiat[2] cases. The length and the depth of the analysis made by the judges of the General Court should be acknowledged, even if certain key issues are perhaps too rapidly dealt with. Although the Commission lost in Starbucks, the

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