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S.Africa: No trade, no deduction: Tax Court issues Section 11(a) judgment

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No trade, no deduction: Tax Court issues Section 11(a) judgment   Cliffe Dekker Hofmeyr South Africa December 15 2017 On April 20 2017 the Tax Court issued its decision in X Group (Pty) Ltd v The Commissioner for the South African Revenue Service (SARS).(1) The case concerned X Group’s(2) claim for R90 million as an expense or loss during the […]

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Africa tax in Brief

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Africa tax in Brief by Celia Becker Africa regulatory and business intelligence | executive cbecker@ENSafrica.com cell: +27 82 886 8744 African Tax Administration Forum launches transfer pricing risk assessment toolkit During the International Conference on Tax in Africa held in Abuja from 26 to 28 September 2017, the African Tax Administration Forum launched its “Toolkit for

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South Africa: Relocating and emigrating from South Africa

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Relocating from South Africa? Key steps to undertake in the emigration process ENSafrica South Africa November 22 2017 There are a number of considerations when relocating to another country that involve much more than a mere physical departure and the taking up of permanent residence in a foreign country. In South Africa, an individual will continue to

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S.Africa: The Davis Tax Committee (the Committee) released a further report on “Tax Administration” on 13 November 2017

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Davis Tax Committee report by Hogan Lovells South Africa November 21 2017 The Davis Tax Committee (the Committee) released a further report on “Tax Administration” on 13 November 2017 as part of the final six reports that were deliverable by the Committee. The report has five chapters covering: Governance of the South African Revenue Service Base Erosion

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OECD Multilateral Convention to Prevent BEPS: Implementation Guide and Initial Thoughts

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OECD MULTILATERIAL CONVENTION TO PREVENT BEPS The final version of the OECD Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) was published at the end of November 2016, and the signing ceremony took place in Paris on 7 June 2017, during which 68 countries covering 69 jurisdictions

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South Africa: Foreign Consultants in SA, & the High Court hears certain Tax Cases

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1. Foreign consultants and services in South Africa 2. The High Court is prepared to hear certain cases At TRM Daniel Erasmus Tax Court Practitioners (daniel@TaxRiskManagement.com) we have advocated successfully that the High Court is the correct forum to address certain tax issues, particularly on interpretation and procedural defects, in certain instances. 1. South African

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INDIA: Impact of the MLI on Indian Tax Treaties – this will be of interest on the effects of the MLI on other countries

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Impact of the MLI on Indian Tax Treaties – this will be of interest to the effects of the MLI on other countries   Daksha Baxi and Ankit Namdeo Khaitan & Co. Mumbai (India) Daksha Baxi is an Executive Director and Ankit Namdeo is an Associate in the Direct Tax Team, Khaitan & Co. Mumbai (India)

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S.Africa: Groundbreaking decision for mining companies

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Groundbreaking decision for mining companies PLUS an important determination: Sars has argued that the high court did not have jurisdiction in the matter, and that it should have been heard by the tax court. The court disagreed and found that it has jurisdiction to hear and determine tax cases turning on legal issues. Firms entitled to

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Advanced Diploma in TP by Thomas Jefferson School of Law

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organised by www.IITF.net, promoted by INFORMA, London Certificate by Thomas Jefferson School of Law Hi, The deadline to submit your application for an Advanced Diploma in Transfer Pricing is fast approaching. Develop an in-depth and practical understanding of transfer pricing as you learn about the latest tax treatments of complex transactions and policy developments that companies need to regularly deal

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