ATL-Editor

S.Africa: Davis Tax Committee final reports April 2018

It’s complete: The Davis Tax Committee releases its final reports Cliffe Dekker Hofmeyr South Africa April 13 2018 On 12 April 2018, the Davis Tax Committee (DTC), issued a media statement (Media Statement) in which it announced the publication of four additional final reports and the conclusion of its work based on its Terms of Reference […]

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S.Africa Tax Court and Appeals: Raising jurisdictional issues

Raising jurisdictional issues Cliffe Dekker Hofmeyr South Africa April 13 2018 Where a taxpayer is dissatisfied with the decision taken by the South African Revenue Services (SARS) regarding an objection made by the taxpayer to an assessment, the taxpayer is entitled to appeal against such decision to the Tax Court. The Rules of the Tax Court,

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US TP the pre-trial memorandum in the Coca-cola intangibles case and various articles

Download a copy here: US TP 2018 Coca Cola case petitioner’s pre-trial memorandum To understand the applicable TP principles applicable in the coca-cola case, read this:  US Transfer Pricing and intangibles explained

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SARS issues new guide to understatement penalties – a march toward further certainty?

SARS issues new guide to understatement penalties – a march toward further certainty? Cliffe Dekker Hofmeyr April 6 2018 The Tax Administration Act, No 28 of 2011 (TAA) was promulgated with effect from 1 October 2012. The rationale behind the introduction of the TAA was that it would streamline, modernise and align the previous tax

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Future expenses deductible now – a judgment about Section 24c of the Income Tax Act

Future expenses deductible now – a judgment about Section 24c of the Income Tax Act Cliffe Dekker Hofmeyr South Africa March 2 2018 Section 24C of the Income Tax Act, No 58 of 1962 (Act) provides for an allowance in respect of future expenditure to be incurred under a contract. On 3 November 2017, the Tax

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US: GILTI onerous for non-C corporation CFC shareholders

GILTI rules particularly onerous for non-C corporation CFC shareholders McDermott Will & Emery USA February 9 2018 Summary The recently enacted tax reform legislation significantly expanded the application of Subpart F, including by adding a new inclusion rule for non-routine CFC income, termed “global intangible low-taxed income” (GILTI). The GILTI rules apply higher tax rates to

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