ATL-Editor

SARS – Being Audited or Selected for Verification

This article was published by South African Revenue Service and the full article is available at: https://www.sars.gov.za/individuals/what-if-i-do-not-agree/being-audited-or-selected-for-verification/ What is verification? Verification is a face-value verification of the information declared by the taxpayer on the declaration or in a return. This involves a comparison of this information against third party data gathered by SARS from various

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Another TP tax dispute argued before the Tax Board in Tanzania won for our client

The Academy of Tax Law would like to congratulate the head of our academics, Dr Daniel N. Erasmus, and his team for another successful transfer pricing tax appeal before the Tax Board in Tanzania. These successes are a testament to our approach in teaching our international taxation and transfer pricing courses. This process has also

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Medtronic vs Commissioner of Inland Revenue

The case of Medtronic, Inc. vs. Commissioner of Internal Revenue revolves around the complex issue of transfer pricing, particularly concerning the appropriate method to determine the arm’s length royalty rates for the use of intellectual property between Medtronic US and its Puerto Rican subsidiary, MPROC.

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From the Controversy Landscape – Code of Conduct Principles of Tax Authorities vs Tax Payers Rights Being Challenged

GTC Conference 2022 The introduction of BEPS has changed the landscape of international taxation. It brought about not only legislative changes but also politically driven changes that may not be feasible in practice. The aim of this conference is to discuss the overall legislative and political implications and consequences of the BEPS project with reference

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Denmark vs EAC: Lessons in Transfer Pricing and Currency Restrictions for Multinational Enterprises

DOWNLOAD THE FULL SUMMARY IN PDF HERE VIEW THE FULL JUDGMENT HERE Case Information Court: Østre Landsret Case No: BS-12642/2020 and BS-25280/2020 Applicant: Ministry of Taxation Defendant: H1, H2 Judgment Date: 20 October 2021 Judgment Summary This case revolves around whether the taxable income of H1 and H2 should be increased under Denmark’s Tax Assessment

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2020/21 Mauritius Budget

BY: Mark Korten – Korten Consulting The Minister of Finance in Mauritius presented the 2020/21 Budget on 11 June 2021. I have waited to see if the Finance Bill that enacts the Budget proposals would be out by now as there is a past precedent in Mauritius of omitting important Budget proposals in the enacting legislation.

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