ATL-Editor

By Slaughter and May The European Court ruled yesterday that the EU Commission had not been able to demonstrate that the advance pricing agreement between Starbucks and the Dutch tax authority amounted to illegal State aid. The Starbucks Dutch company concerned was responsible for buying and roasting coffee beans and supplying these, and other consumables, […]

13 September 2019 Jean Du Toit, Senior Attorney at Tax Consulting SA The Supreme Court of Appeal (SCA) delivered a judgment on 6 September 2019 that handed SARS one of their most influential wins in recent times. The SARS Commissioner did not pull any punches and took BMW South Africa to task on tax services

The IFA Congress 2019, held 8-12 September in London, brought together leading international tax and transfer pricing experts from around the world. As a part of a four-day scientific programme, the experts presented and debated on two main subjects, interest deductibility and the taxation of investments funds, and on a wide range of other topics,

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We prepared to argue an application for default judgment against SARS in the Tax Court on 13 September 2019. SARS were very late in filing their opposing papers, as they were with everything else leading to the default judgment application in the first place. We ended up not arguing the case as SARS settled the

Advanced Postgraduate Diploma in Transfer PricingCourse Start Date: 28th October 2019Delivered by Tutored Distance Learning Do you wish to develop an in-depth and practical understanding of Transfer Pricing as well as examine the latest policy developments and tax treatment of complex TP transactions that you and your organisation need to deal with in an increasingly demanding regulatory environment? If so, you will be

ENSafrica – Simon Weber and Mike Benetello “There can be no objection in principle to the deduction of interest on loans in suitable cases. Loan capital is the life blood of many businesses but the mere frequency of its occurrence does not bring about that this type of expenditure requires different treatment.” Whilst these words of Hefer JA in

16/09/2019 – The first OECD Tax Certainty Day took place today at OECD headquarters in Paris. As recognised by G20 Ministers, maintaining and enhancing tax certainty brings benefits for taxpayers and tax administrations alike and is key in promoting investment, jobs and growth. This is particularly the case against the backdrop of the rapid digitalisation

ENSafrica OECD, South Africa September 10 2019 South Africa has transfer pricing legislation which generally applies to cross border transactions between connected persons. This is achieved through the reference to an “affected transaction” in section 31 of the Tax Act, which in turn refers to a “connected person” as defined in section 1 of the Tax Act.

September 12, 2019 By Ruth Butter & Stefan Sunde at TP EQuilibrium AustralAsia The Federal Court of Australia on 3 September issued its much-anticipated judgment Glencore Investment Pty Ltd v Commissioner of Taxation of the Commonwealth of Australia [2019] FCA 1432, herein referred to as the Glencore decision. First, the Court found that the Commissioner of the Australian