ATL-Editor

Fiat Chrysler Finance Europe and Ireland v Luxembourg: State Aid, Transfer Pricing, and the Arm’s Length Principle

The case involves two appeals by Fiat Chrysler Finance Europe (formerly Fiat Finance and Trade Ltd) and Ireland, challenging the General Court’s decision to uphold a European Commission ruling that a tax ruling granted by Luxembourg to Fiat Chrysler Finance Europe constituted unlawful state aid.

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TANZANIA: Licensing of Tax Consultants – A clog/fetter to taxpayer’s right to representation?

Published by: B&E Ako Law Taxpayers are now required to be represented by licensed tax consultants only. A representation by any other person seems to have no legal effect. This legal requirement was introduced on 1 July 2022 by the Tax Administration (General) (Amendment) Regulations, 2022. This updater looks into this legal requirement and other

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SOUTH AFRICA: Replacement of IT14SD forms – New SARS Verification Process

AUTHOR: Ziyaad Moosa – PKF Octagon (Johannesburg) With effect from 16 September 2022, The South African Revenue Services (SARS) discontinued the use of the IT14SD return. This return was previously used by SARS where a taxpayer was selected for verification (which is a high level review of the taxpayer’s income tax return). The IT14SD return

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NIGERIA: VAT and the Reverse Charge Mechanism in Nigeria

Article by: Abdulateef Olatunji ABDULRAZAQ (Founder, Taxmobile.Online) Introduction  Value Added Tax (VAT) is a consumption tax imposed on the value of the supply of taxable goods and services produced and consumed in Nigeria. The Finance Act (FA)2020 generally defines taxable supplies of goods and services as supplies received and consumed by a person in Nigeria,

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So is a foreign pension trust not actually a trust? (South African Tax)

Published by: Regan van Rooy Unpacking the recent SARS ruling on foreign pensions On 22 August 2022, the South African Revenue Service (SARS) published binding class (“BCR”) ruling 080, which quickly became the talk of the town, or certainly the talk of the SA tax community.  So what was so interesting? Well, basically SARS ruled

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