ATL-Editor

29 April 2019 In the wake of another budget deficit, SARS looks toward South Africans living abroad to help close the gap. A recent amendment to section 10(1)(o)(ii) of the South African Income Tax Act No.58 of 1962 (‘the Act’), as part of the Taxation Laws Amendment Bill of 2017, has attracted tremendous international attention […]

Google parent company Alphabet reported recently its full-year results for 2018, announcing income of $30-billion off a revenue of $137-billion. But the eye-popping thing about the earnings statement was that its tax bill was just $4.2-billion, 12{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e} of its pre-tax income, which was less than the $5-billion it paid in fines to the European Union.

GHANA: High Court rules that payment of minimum disputed amount is a prerequisite for filing an appeal The Commercial Division of the High Court, in its decision of 13 July 2018, in the case of Beiersdorf Ghana Limited v. The Commissioner General of the Ghana Revenue Authority (CM/TAX/0001/2018), ruled that the payment of at least

Country-by-Country Reporting and Transfer Pricing SARS issued a public notice on 20 October 2017 which stipulates the requirements and timeframes for Country-by-Country Reporting (“CbCr”) and transfer pricing documentation (master file and local file).  The requirements for CbCr which apply for financial years commencing on or after 1 January 2016 is a consolidated Multi-National Entities (“MNE”) group turnover

Here is a FULL copy of the case. Although there is a useful summary below, read the full case for yourself: http://iitfconnect.com/wp-content/uploads/2019/04/Nestle-vs-ZRA-TP-Case-2019.pdf On March 28, 2019, the Tax Appeals Tribunal (TAT) delivered its decision in Nestlé Zambia Trading Limited v Zambia Revenue Authority [2018] TAT 03. The case is very likely to have important future implications for

Budget speech tax proposals: http://www.treasury.gov.za/documents/national{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20budget/2019/review/Annexure{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20C.pdf SARS’ own tax guide: http://www.treasury.gov.za/documents/national{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20budget/2019/sars/Budget{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}202019{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Tax{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Guide.pdf

Cliffe Dekker Hofmeyr In the international tax law arena, agreements for the avoidance of double taxation (DTAs) are, very simply, concluded between states with a view to prevent, mitigate or discontinue the levying of tax in respect of the same income, profits or gains or tax imposed in respect of the same donation under the