ATL-Editor

AFRICA: Sub-Saharan Africa and international arbitration – how does that work?

COMMENT Tax arbitration via new double tax treaties is on the increase. Hence, knowledge of international arbitration is important. Take a look at the following extract from the IBFD Book – Arbitration under Tax Treaties: http://www.ibfd.org/sites/ibfd.org/files/content/pdf/ArbitrationunderTaxTreaties_sample.pdf This will complement the provisions of the mutual agreement procedure, which correspond exactly to the wording of Article 25(1) to (4) OECD Model, by adding the following paragraph (5): […]

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S.AFRICA – The first foray by the Supreme Court of Appeal into SARS’ audit duties

Another article about this case is available here – http://taxriskmanagement.com/sca-judgment-on-sars-conduct/ In the case of CSARS v Pretoria East Motors Pty Ltd, (291/12) [2014] ZASCA 91 (12 June 2014) the court sought to look at certain principles from the Income Tax Act 58 of 1962 and the VAT Act 89 of 1991 regarding an appeal against the

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MM Zambia Limited v. Zambia Revenue Authority

MM Zambia Limited v. Zambia Revenue Authority (2014/HP/0100) in the High Court for Zambia, Holden at Lusaka, before the Honourable Mr. Justice C.F.R. Mchenga S.C. The matter was an urgent judicial review on the grounds of illegality and unreasonableness sought by the Applicant (MM) against the Respondent (ZRA) seeking to overturn the ZRA’s decision to

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S.Africa 2001 – Sars has jumped the gun, says Khoza’s lawyer

Sars has jumped the gun, says Khoza’s lawyer SOUTH AFRICA / 26 AUGUST 2001, 2:51PM /  The lawyer representing Irvin Khoza, the Orlando Pirates soccer boss, on Sunday accused the South African Revenue Service (Sars) of violating his client’s rights by divulging details of an agreement reached with him. Khoza, who is the chairman of the Orlando Pirates

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