ATL-Editor

Transfer pricing disputes to threaten big companies’ profit growth

Transfer pricing disputes to threaten big companies’ profit growth Postgraduate Diploma in Transfer Pricing | Starts 29 Oct 2018   Transfer pricing related tax disputes are the most common source of conflict expected to wipe out half of the profit growth of top US companies*. This trend is global and companies might not be able to escape regulators’ fury […]

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S.Africa: When does tax avoidance apply

By ENSAfrica Groups of companies often wish to restructure or rationalise their operations. This generally involves a transfer of companies and/or assets between various entities. There are many commercial drivers for such transactions. There are also a variety of ways in which the group can achieve its commercial goals. Depending on how the transactions are

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Zimbabwe slaps ‘catastrophic’ tax on electronic transactions

Zimbabwe slaps ‘catastrophic’ tax on electronic transactions Zimbabwe’s newly appointed Finance and Economic Development Minister Mthuli Ncube has announced a 2 cents per dollar tax on electronic transactions as the country moves to widen its tax base. “I hereby review the Intermediated Money Transfer Tax from 5 cents per transaction to 2 cents per dollar

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Africa: Internet taxes

The growth in online media platforms has caught a number of African countries off guard. Some, including Kenya, Tanzania, Uganda, and Zambia, have taken steps to control online activity – the playground for the shadow economy. The approaches have ranged from introducing new taxes to passing new restrictive laws and internet taxes. George Ogola warns

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Canada: TP case – Cameco’s Canada Tax Court Victory Brings Relief for Companies

Canada: Cameco’s Canada Tax Court Victory Brings Relief for Companies • Court rejects government’s arguments of “sham” transactions • Lawyers divided on whether ruling harms OECD base-erosion reforms By Peter Menyasz Companies should rest easy knowing that they can arrange their tax affairs as they see fit—as long as the approach is legal—after uranium giant Cameco Corp.

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Africa: The Rising Tide of Tax Disputes

The Rising Tide of Tax Disputes 02 October 2018 By JJ van der Walt, Candidate Attorney, and Arnaaz Camay, Tax Executive, Tax Practice, Baker McKenzie Johannesburg New research from Baker McKenzie, The Shape of Water: Tax Disputes in the Age of Intangible Value, shows that the amount of tax under dispute in Fortune 500 companies

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GHANA: High Court rules that payment of minimum disputed amount is a prerequisite for filing an appeal

GHANA: High Court rules that payment of minimum disputed amount is a prerequisite for filing an appeal by Renier van Rensburg 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

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S.Africa: Cons Court – when can an official (SARS and others) be held personally liable for damages?

Black Sash Trust (Freedom Under Law Intervening) v Minister of Social Development and Others (Corruption Watch (NPC) RF and South African Post Office Soc Limited as Amici Curiae) Case Number: CCT48/17C Citations: [2018] ZACC 36 Judge: Froneman J Judgment Date: 27 September 2018 Case History: This judgment deals with the issue of costs left open

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S.Africa: No tax deduction for damages paid for deliberate breach of supply contract

by Cliffe Dekker Homeyr – Ben Strauss and Jerome Brink South African courts have held, on a number of occasions, that taxpayers are entitled to deduct damages or compensation paid to third parties. However, this principle does not apply in all cases. The case of Kangra Group (Pty) Ltd v Commissioner for SARS (Case number A20/18) was recently heard by

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