ATL-Editor

Transfer Pricing in mining with a focus on Africa by Steef Huibregtse (TP Associates) and others

http://documents.worldbank.org/curated/en/801771485941579048/pdf/112346-REVISED-Dated-Transfer-pricing-in-mining-with-a-focus-on-Africa-a-reference-guide-for-practitioners-Web.pdf PART OF THE PRECIS: The World Bank Group, led by the Energy and Extractives Global Practice, has been at the forefront of offering advice on good practices, as well as on undertaking diagnostic visits and building capacity of developing countries on mineral tax administration. It has adopted a phased approach—wherein it undertakes research and […]

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Transfer Pricing Toolkit to Give African Tax Authorities Clout

Transfer Pricing Toolkit to Give African Tax Authorities Clout • Interventions have brought in over $120m tax revenue in two years • Toolkit empowers authorities to assess transfer pricing risks By Marcia Klein The African Tax Administration Forum has published a toolkit (https://www.ataftax.org/en/products-services/technical-assistance/transfer-pricing-tp) for transfer pricing and risk assessment in the African mining sector, with the help of Germany’s Federal

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SEC Roundup: Various MNEs Report IRS Transfer Pricing and related Adjustments and the SASOL tax case in S.Africa

SEC Roundup: Various MNEs Report IRS Transfer Pricing and related Adjustments By Sony Kassam Dell Technologies Inc., a Texas-based information technology company, reported that the IRS Office of Appeals is reviewing its federal income tax returns for 2007-09 and that the agency proposed transfer pricing adjustments for those years, according to a filing with the Securities and Exchange

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SEC Roundup: Various MNEs Report IRS Transfer Pricing and related Adjustments

By Sony Kassam Dell Technologies Inc., a Texas-based information technology company, reported that the IRS Office of Appeals is reviewing its federal income tax returns for 2007-09 and that the agency proposed transfer pricing adjustments for those years, according to a filing with the Securities and Exchange Commission. In addition, Analogic Corp. reported that it accrued

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S.Africa: MFN clause in RSA and Netherlands DTA and some additional info

Read the latest PwC Synopsis on the case first: http://www.pwc.co.za/en/assets/pdf/synopsis-september-2017.pdf?utm_medium=email&utm_source=sharpspring&sslid=MzIxMDA2tjA0NDEzAAA&sseid=MzQ1NzM3MbAwswAA&jobid=84ad69aa-fb01-4f43-a4a9-0182ea1b4103 The Most Favoured Nation clause appears in the General Agreement on Trade (GATT) and General Agreement on Trade and Services (GATS) of the WTO. Most nations are members of the WTO, and the agreement would be considered to be customary international law. The MFN and

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BEPS (2017) Action 13 CbC Reporting Handbook on Effective Tax Risk Assessment

BEPS (2017) Action 13 CbC Reporting Handbook on Effective Tax Risk Assessment OECD (2017), Country-by-Country Reporting: Handbook on Effective Tax Risk Assessment, OECD, Paris. OBTAIN YOUR COPY HERE: http://www.oecd.org/tax/beps/country-by-country-reporting-handbook-on-effective-tax-risk-assessment.htm Table of contents  Abbreviations and Acronyms ………………………………………………………………………………………………………..7  Chapter 1 Introduction and Background………………………………………………………………………………………9  Chapter 2 The Role of Tax Risk Assessment in Tax Administration…………………………………………….15  Current developments in

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S.Africa: Does a tax audit constitute “administrative action” under PAJA

This is a reprint of an earlier article – but still very relevant today: What follows is a discussion that is relevant to South African tax law, read with the Constitution and administrative law, which may apply in various other African jurisdictions as well: Introduction Viking Pony Africa Pumps (Pty) Ltd t/a Tricom Africa v Hidro-Tech Systems

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Foreword to a series of papers on managing tax risk post BEPS

Foreword to a series of papers on managing tax risk post BEPS The TRM Seven Steps Special Report is based on more than 120 lectures presented to many multi-national corporations (MNEs) and smaller businesses (SMEs) looking to minimize one of the largest financial risks facing them: Tax! We hope that these notes and extracts will demonstrate

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UN handbook on tax avoidance includes new chapters on rents, royalties, GAAR

UN handbook on tax avoidance includes new chapters on rents, royalties, GAAR This is relevant to developing nations in Africa September 11, 2017 Featured News, Transfer Pricing published by mnetax.com The UN has published the second edition of the United Nations Handbook on Selected Issues in Protecting the Tax Base of Developing Countries, updating the manual and adding new

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Africa Tax Journal – Read for Free

www.AfricaTaxJournal.com Enlist at www.ErasmusOnTax.com and subscribe for the FREE eBook on Tax Risk Management a summary of the book Tax Intelligence: The 7 Habitual Mistakes Companies Make available on Amazon.com at: https://www.amazon.com/Tax-Intelligence-Habitual-Mistakes-Companies/dp/145006874X A blog post to listen to the articles is being developed. Future blogs include enlightening blog interviews with key players in Africa Tax. Articles to be published include: An update on

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