ATL-Editor

Many have observed that technology will free up time for lawyers to engage in more strategic and higher value activities. To be better problem-solvers, more commercial and more creative. What do these concepts mean? What kinds of skills are involved?You often hear clients describe a good lawyer as someone who is commercial, practical, creative, strategic, etc. But […]

AI Robotics the future taxes – A US perspective-2 Why the OECD investigation direction on the digital economy and taxation may fail, because they do not clearly understand  what is happening with the current blockchain technological revolution. By Prof. Dr. Daniel N. Erasmus daniel@taxriskmanagement.com www.TaxRiskManagement.com

My view – where cryptocurrency is held as a currency to buy goods or services, when its value is released on buying those goods or services as a currency, there should be no tax consequence.  Just like when you hold dollars, that are converted to Rands when you buy goods and services. You are not

The brochure: TPA Global Tax Controversy – Workshop for Corporates Some large corporations are in attendance in personalized small workshops. You are invited to attend. http://www.tpa-global.ccom/gtc2018  

Curriculum – AD Transfer Pricing 2018 vr6 Please note that the tutorial questions and the assignments are embedded in the Curriculum Spreadsheet with hyperlinks to make it easier to prepare. But the essential reading materials are set out below, with addition up-to-date reading you should be doing as changes are made by the OECD and other

Curriculum – New Curriculum vr5 Please note that the tutorial questions and the assignments are embedded in the Curriculum Spreadsheet. Reading materials per lecture – http://iitfconnect.com/?p=1040 Prescribed reading materials: International Tax Primer 3rd Edition Brian Arnold – eBook Victor Thuronyi Comparative Tax Law Basic International Taxation Vol I by Roy Rohatgi – eBook UN Model Double Taxation Convention

Why is tax one of the biggest business risks in Africa, that interlinks with corruption? Corrupt officials and governments use the desperately needed tax funds for social uplifting and development in a corrupt manner. This places more pressure on the fiscus to collect more taxes. MNEs then start facing ambitious, but often wrong tax assessments

The facts are set out here: Facts The moot judgment: Disputes Mauritius Legit Expect judgment The supporting documents: TP SARS Practice Note 7 Income Tax Practice Note 7 of 1999 SARS arguments Legitimate Expectation note OECD How Acquiescence and Estoppel legally bound to OECD commentaries by Frank Engelen Unilever Kenya Ltd v Commissioner KRA Income

https://www.ensafrica.com/news/Africa-Tax-in-Brief?Id=3034&STitle=Africa#

A recording of the lecture (with a Portuguese translator): the introduction for accounting and law students ends at 34 mins, and then the more technical lecture starts: https://www.dropbox.com/s/lklvsheuxlk2gdc/Lecture{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20suppl{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20New{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Moz{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20TP{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20regulation{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}2014{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20May{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}202018.m4a?dl=0 Powerpoint presentation:  Mozambique TP Dispute Resolution Presentation The slides on the 6th method were not covered due to time issues, but nevertheless contain useful information. These are the