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SOURCE: of Constitutions of various Countries http://www.wipo.int/wipolex/en/ The above link not only introduces you to various treaties and laws per country on IP issues (relevant to transfer pricing issues), but also gives you access to the latest Constitutions. In tax law, Constitutions are important to establish if: – the Constitution is the Supreme Law and

This online seminar is presented by Prof. Dr. Daniel N. Erasmus and Schalk Pieterse, both experienced practitioners in this field. The 2 have worked together on numerous cases where Erasmus has been  instructed by Pieterse to argue the tax dispute matters in court as Counsel. Here are the PPT presentation slides: DISPUTE RESOLUTION WEBINAR 26

By ENS Section 9D of the Income Tax Act, 1962 (the “Act”) is aimed at South African residents who directly or indirectly hold more than 50{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e} of the total participation (broadly speaking shares) or voting rights in a foreign company. A foreign company in this context is classified as a controlled foreign company (“CFC”). In

The OECD released two reports containing Guidance for Tax Administrations on the Application of the Approach to Hard-to-Value Intangibles, under BEPS Action 8; and Revised Guidance on the Application of the Transactional Profit Split Method, under BEPS Action 10. In October 2015, as part of the final BEPS package, the OECD/G20 published the report on Aligning Transfer

Many countries have become more focused on combating tax avoidance. As such, transfer pricing compliance has become much more burdensome due to substantial documentation requirements and multiple filing deadlines. Multinationals (“MNEs”) have to take action to control their transfer pricing risks, but the cost of doing so could substantially increase. Before base erosion and profit

Today, the OECD and the African Tax Administration Forum (ATAF) signed a renewal of their Memorandum of Understanding (MoU) until June 2023, agreeing to continue to work together to improve tax systems in Africa. The MoU sets their co-operation towards the achievement of the common objective of promoting fair and efficient tax systems and administrations

Recently, the Supreme Court of Appeal (“SCA”) upheld a ruling handed down by the High Court in Pretoria 2 years ago, setting aside an exorbitant rates regime implemented by the City of Tshwane Metropolitan Municipality. The unlawful property rates regime arose following the amalgamation of the former Kungwini Municipality into the City of Tshwane. When

SARS MAP Guide DRAFT 2018 Draft Guide on MAPs CONTENTS Preface…………………………………………………………………………………………………………………ii Glossary ………………………………………………………………………………………………………………1 1. Background ……………………………………………………………………………………………….1 1.1 What is a mutual agreement procedure?………………………………………………………………………..2 1.2 Legal basis for mutual agreement procedure ………………………………………………………………….5 1.3 Multilateral Instrument………………………………………………………………………………………………….6 1.4 The role of a competent authority ………………………………………………………………………………….7 1.5 South Africa mutual agreement procedure profile and website………………………………………….7 2. In what instances

More on blockchain and the cryptocurrency – Ethereum Well to quote Blockgeeks: Every single operation that takes part in Ethereum, be it a simple transaction, or a smart contract, or even an ICO takes some amount of gas. Gas is what is used to calculate the amount of fees that need to be paid to