ATL-Editor

Audits Microsoft, J&J Tax Heads Divulge Tax Feud Strategies Snapshot • Johnson & Johnson uses software tool to keep track of business narrative and audits • Companies should look to the future when assessing risk on tax positions: Microsoft tax counsel By Sony Kassam Microsoft and Johnson & Johnson tax officials say companies must figure out how to […]

On 25 July 2018, the South African Revenue Service (SARS) published its Guide on Mutual Agreement Procedures (Guide) as a general guidance on the Mutual Agreement Procedure (MAP), providing parameters in which competent authorities from the governments of contracting jurisdictions can interact with the intent to resolve international tax disputes. Finding the MAP MAP is

A transcript of a Podcast by Prof. Dr. Daniel N. Erasmus Today I have been asked to talk to you about the question of verification versus audits by the Commissioner in terms of the Tax Administrative Act (TAA) for those of you obviously who are taxpayers, and from time to time, might receive notification from

If your entity is owned by a US entity (whole or part) this will affect you and the US holding entity. US IRS issues first set of GILTI tax regulations September 13, 2018 The US IRS today issued its first set of proposed regulations on the global intangible low-taxed income (GILTI) provisions added in the

OECD updated its guidance on country-by-country reporting for multinationals, providing clarifications to assist taxpayers and tax administration, The new guidance, approved by the “Inclusive Framework on BEPS,” a coalition of over 100 countries, aims to answer questions that have risen as the country-by-country reporting scheme has moved to the implementation phase. The OECD said in a

In Rampersadh and Another v Commissioner of the South African Revenue Service and Others(5493/2017) [2018] ZAKZPHC 36 (27 August 2018), the KwaZulu-Natal Division of the High Court had to consider the provisions of s93 of the TAA, where the applicant taxpayers (Taxpayers) lodged a review application. Specifically, the Taxpayers requested the High Court to review SARS’s decision

By ENSafrica The South African Draft Taxation Laws Amendment Bill, 2018 (the “Draft Bill”), which was published by the Minister of Finance on 16 July 2018, introduces many of the tax proposals announced in the 2018 Budget Review earlier this year. Consistent with the general trend of combatting perceived areas of tax avoidance, among the

Litigation Court Roundup: Updates in Facebook, Eaton and Coca-Cola Tax Cases The IRS, in Facebook Inc.’s latest challenge in the U.S. Tax Court, rejected the social network’s claim that it properly valued intangibles, including Instagram technology, that the company transferred to its Irish unit in 2013. The Internal Revenue Service also denied Facebook’s statement that

Mukesh Butani (BMR Legal) and Ashrita Prasad Kotha (Jindal Global Law School)/August 22, 2018 India introduced the place of effective management (POEM) in its domestic law in Finance Bill of 2015 but due to lack of preparedness it was deferred to April 1, 2017 and made applicable from assessment year 2017-2018. The statement of intent revealed that the purpose

GDP of the USA – US$ 18.57 trillion              Population – 325.7 million   GDP of Brazil – US$ 1.3 trillion                          Population – 207.7 million GDP of Russia – US$ 1.8 trillion