ATL-Editor

Zambia seeks USD22-million in tax on internet calls Zambia expects to raise USD22-million annually in new tax on internet phone calls. The cabinet approved a 30 ngwee (0.3 kwacha; USD0.03) daily tariff charged on online phone calls. Transport and Communications Minister Brian Mushimba said that the government considered concerns raised by telecom operators. He added […]

SARS publications  interpretation note 4 (issue 5): resident: definition in relation to a natural person – physical presence test section 1(1) of the Income Tax Act, 1962 (the “Act”). find a copy of this updated interpretation note here.

Australia 2015 Article 9 Chevron Australia Holdings (Pty) Ltd v CoT [2015] FCA 1092 Australia Appeal 2017 Chevron Australia v Comm of Tax [2017 FCAFC 62] Australia Roche Products Pty Ltd (NT 2005_7 & 56-65) Australia-SNF-Australia-Pty-Ltd-v-Commissioner-of-Taxation-2010-FCA-635-25-June-2010 Canada GE Capital [2010 FCA 344] CanLII – 2010 FCA 344 (CanLII) Canada GE Capital [2010 FCA 344] summary

Note by Prof. Dr. Daniel N. Erasmus: We have experience in representing clients at these  inquiries. The SARS powers are extensive. It is very difficult to challenge the access by SARS to this type of inquiry once they present prima facie evidence that falls into the provisions of sections 51-58 of the TAA. What is important is

https://www.pwc.co.za/en/assets/pdf/synopsis/synopsis-july-2018.pdf?utm_medium=email&utm_source=sharpspring&sslid=MzIxMDA2tjA0NDEzAAA&sseid=MzQzMLM0MjGyNAIA&jobid=d183246e-9a44-4062-9d4f-929180993b19 PwC provides a great summary each month of key tax cases in South Africa. This edition deals with these important  judgments: The SARS discretion with trading stock – Tax Court, in Case No. 13626 (judgment delivered on 18 May 2018), the court was asked to consider whether the adoption of IFRS principles was a

NOTE FROM PROF. DR. DANIEL N. ERASMUS: The key part of the article below is the following, which speaks to the situation in South Africa and TP adjustments. SARS has a discretion to adjust taxable income if they believe an ALP has not been charged, but this must be substantiated with evidence which they produce.

Malawi tax collector loses case against Eastern Produce For a copy of the judgment: https://www.dropbox.com/sh/8v1vx14n3hrgky4/AABzcqbi3yExqT14DGRqylDNa?dl=0 BY FESTON MALEKEZO: The High Court in Blantyre has ruled in favour of the multi-national Eastern Produce Limited in a K1.6 billion transfer pricing case with Malawi Revenue Authority (MRA). Eastern Produce has agricultural and horticultural operations in Kenya, Malawi and

Analyzing Value Chains in Business Models Impacted by the Digital Economy Digitization has given rise to new firms and industries, besides altering the traditional business models and reshaping the global economy. That is a reasonable reason why companies have to evolve the way they conduct a Value Chain Analysis (VCA), in order to be streamlined for digital businesses.

Tax Intelligence book I wrote a book on tax risk management that includes tax and strategy. It is called TAX INTELLIGENCE and is available on Amazon. https://www.amazon.com/Tax-Intelligence-Habitual-Mistakes-Companies/dp/145006874X However, I am willing to send free pdf copies to those who request it – please send your requests to daniel@TaxRiskManagement.com. I will also send you a summary version.

http://www.sars.gov.za/AllDocs/OpsDocs/Guides/LAPD-IT-G24{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20-{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Guide{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20on{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Mutual{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Agreement{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Procedures.pdf South Africa Report from Prof. Johann Hattingh, University of Cape Town Revenue Service issues final Guide on Mutual Agreement Procedures under tax treaties On 25 July 2018, the South African Revenue Service (SARS) issued a final Guide on Mutual Agreement Procedures (MAP). For earlier coverage, see South Africa-1, News 22 May 2018. The Guide