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Transfer Pricing: Corporate LiveWire Round Table on TP in 2015

Leave a Comment / Africa /

Transfer Pricing 2015 In our Transfer Pricing Roundtable we spoke with nine experts from around the world to discuss the recent regulatory changes and interesting developments in their jurisdiction. Our chosen experts analyse the different pricing methods currently being implemented and discuss the challenges posed by a recent explosion of rules and regulations surrounding base […]

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USA: “IRS Makes Changes to Offshore Programs; Revisions Ease Burden and Help More Taxpayers Come into Compliance“

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The new revisions to the US offshore voluntary disclosure program, which we posted on 6/18/14 “IRS Makes Changes to Offshore Programs; Revisions Ease Burden and Help More Taxpayers Come into Compliance“, now provides for an increased 50{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e} FBAR Penalties for ‘Willful’ Non-Disclosers. This group includes those individuals who have offshore bank accounts with a foreign

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Transfer Pricing – Adv Diploma offered through the Thomas Jefferson School of Law

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Dear Applicant, Transfer pricing has become a major problem with international multinationals, particularly in developing countries. Revenue services are becoming more skilled in the area of transfer pricing, and every year sees a dramatic increase in companies being required to engage with revenue services on transfer pricing. The International Institute for Tax & Finance (IITF), in association with Thomas Jefferson

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Treaty between Mauritius and South Africa enters into force

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Treaty between Mauritius and South Africa enters into force On 28 May 2015, the Mauritius – South Africa Income Tax Treaty (2013) entered into force. The treaty generally applies from 1 January 2016. From this date, the new treaty generally replaces the Mauritius – South Africa Income Tax Treaty (1996). For details of the new

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Africa: S.Africa and other similar jurisdictions – the AUDIT engagement letter

Leave a Comment / Africa, Nigeria, SADC, South Africa, West Africa, Zambia /

SURVIVING A TAX AUDIT UNDER THE TAX ADMINISTRATION ACT, 2011 Presented by Prof. Dr. D N ERASMUS Tel: 083 458 8422 or +1.561.568.7115 E-mail: daniel@TaxRiskManagement.com www.TaxRiskManagement.com Introduction Viking Pony Africa Pumps (Pty) Ltd t/a Tricom Africa v Hidro-Tech Systems (Pty) Ltd & another 2011 (1) SA 327 (CC) para [37]: …PAJA defines administrative action as

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Nigeria: A Landmark TAT decision in a VAT case on imported services

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PwC secures a Landmark TAT decision in a VAT case on imported services In brief On 10 June 2015, the Tax Appeal Tribunal (TAT) sitting in Abuja held that foreign companies providing services outside Nigeria to Nigerian companies are not carrying on business in Nigeria for the purposes of the Nigerian Value Added Tax (VAT).

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S.Africa: SARS Issues Binding Private Ruling on Cross Border Interest-Free Loan, Withholding Tax on Interest

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South Africa Revenue Service Issues Binding Private Ruling on Cross Border Interest-Free Loan, Withholding Tax on Interest The South African Revenue Service (SARS) May 28 issued Binding Private Ruling (BPR) 192 on whether an adjustment made to taxable income or tax payable under Section 31 of the Income Tax Act No. 28 of 1962 can

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Mauritius, South Africa Sign MOU on Dual Residency Status Under DTA

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The Mauritian Revenue Authority May 22 signed a memorandum of understanding (MOU) with the South African Revenue Service concerning the application of the provision of Article 4(3) of the double taxation agreement (DTA) between Mauritius and South Africa signed May 17, 2013, which addresses the issue of dual residency status of corporate taxpayers. [Mauritius, Mauritius

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S.Africa: Exchange of information agreement between South Africa and St. Kitts and Nevis signed

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Exchange of information agreement between South Africa and St. Kitts and Nevis signed On 17 April 2015, South Africa and St. Kitts and Nevis signed an exchange of information agreement relating to tax matters, in Basseterre, St Kitts and Nevis. Further details will be reported subsequently. Treaty texts are published in the Treaties collection on

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