FP News

TP Minds conference in Johannesburg: TP case update by Prof. Dr. Daniel N. Erasmus

Below is a link to the short presentation on the latest Africa TP cases and the experience of Dr. Erasmus arguing tax cases in various African jurisdictions. He also shares the techniques on how to avoid tax litigation: https://www.dropbox.com/s/6uosb1j07goq0ws/TP{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Minds.mp4?dl=0

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TP judgments in Africa – as at Nov 2019

Here is a list of  the current cases: The first Ghana TP  case – TP Ghana JUDGMENT IN TAX APPEAL CASE BETWEEN BIERSDORF GH LTD AND THE COMM GENERA… The first RSA TP related case – Crookes Brothers Ltd v Commissioner for the South African Revenue Service [2018] ZAGPHC 311 (judgment delivered 8 May 2018) This is  a

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Africa Brief 28 Oct 2019

Africa Doing Business 2020: Two sub-Saharan African countries among most improved in Ease of Doing Business Economies in sub-Saharan Africa continued to improve their business climates, with the region’s largest economy, Nigeria, earning a place among the year’s top global improvers alongside Togo, according to the World Bank Group’s Doing Business study. Economies of the

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UN: Practical Manual on Transfer Pricing

As the OECDThe Organisation for Economic Co-operation and Development (OECD) is an international organisation comprising 38 member countries, established to foster economic growth, trade, and development on a global scale. Founded in 1961, the OECD provides a forum for governments to collaborate, share policy experiences, and develop solutions to common economic challenges. The OECD’s core

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Africa tax in brief

22 OCT 2019 ENSafrica – Celia Becker ANGOLA: Treaty with Portugal enters into force On 22 August 2019, the Angola-Portugal Income TaxIncome Tax is a direct levy imposed by governments on the income generated by individuals, corporations, and other entities within a specific jurisdiction. It serves as a major source of revenue for governments and

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Combatting Tax Crimes More Effectively in APEC Economies

Tax evasionTax Evasion refers to illegal activities or practices undertaken by individuals or businesses to avoid paying taxes. It involves intentionally misrepresenting or concealing income, inflating deductions, or underreporting earnings to reduce tax liability unlawfully. Unlike tax avoidance, which uses legal methods to minimize tax obligations, tax evasion is a criminal offence that carries significant

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Exchange of information: disputes multiply

Jonathan Schwarz (Temple Tax Chambers; King’s College London)/October 14, 2019  Some four years ago in this blog, I wrote about problems that would start to emerge as exchange of information between tax administrations became more routine and extensive.  If nothing else, the number of disputes in this area was bound to increase. See also Exchange of Information: bumps in

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OECD Consulting on Digital Tax

The OECD published for stakeholders’ comments a proposal to advance international negotiations to ensure that multinational enterprisesWhat are Multinational Enterprises (MNEs)? Multinational Enterprises, commonly referred to as MNEs, are corporations that operate in multiple countries through various subsidiaries, branches, or affiliates. These entities maintain a central management structure while leveraging diverse resources, labour markets, and

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NEW book: Transfer Pricing and Value Creation

Recently published:Petruzzi/TavaresTransfer PricingTransfer pricing is a fundamental concept in international taxation that defines the pricing methods and rules applied to transactions between related entities within a multinational enterprise (MNE). In the context of tax regulations, it governs how prices for goods, services, or intangibles (such as intellectual property) are set when these items are exchanged

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