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SSRN Research Papers download – Tax Planning and other Papers to download

SSRN Research Papers Congratulations Dr Daniel N Erasmus You are currently in the top 10{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e} of Authors on SSRN by all-time downloads. Check out your Research Papers on SSRN. https://papers.ssrn.com/sol3/cf_dev/AbsByAuth.cfm?per_id=990830 1. Tax Planning as Part of a Tax Risk Management ProcessThomas Jefferson School of Law Research Paper No. 1482423Number of pages: 88 Posted: 04 Oct 2009 Last Revised: […]

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TRANSFER PRICING BUSINESS MODELS

By Angela Sadang  |  January 27, 2017  |    Download PDF  Once the initial transfer 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

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S.Africa: Win for the employer: Judgment on the Employment Tax Incentive Act

By CDH Cliffe Dekker Hofmeyr – Louis Botha and Louise Kotze In the recent case of ABC (Pty) Ltd v The Commissioner for the South African Revenue ServiceThe South African Revenue Service (SARS) is the official tax authority responsible for the administration and enforcement of tax laws in South Africa. It plays a crucial role in managing the country’s

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Global Tax Alert: Dutch Supreme Court confirms dividend withholding tax exemption under treaty between South Africa and the Netherlands

DLA PIPER In our Global Tax Alert on February 5, 2018, we discussed the decision of the Dutch Court of Appeal (‘s-Hertogenbosch) which held that dividend distributions from Dutch entities to South African entities are effectively exempt from Dutch dividend withholding tax pursuant to the most favored nation (MFN) clause in the tax treatyA Double Taxation Agreement

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S.Africa: When must a reportable arrangement be disclosed to SARS?

By Ben Strauss, Cliffe Dekker Hofmeyr Attorneys Under the Tax AdministrationTax authorities are fundamental institutions within government frameworks, overseeing tax assessment, collection, and administration. Their operations ensure that tax laws are enforced and public funds are collected efficiently. This article delves into tax authorities’ purpose, responsibilities, and structure, offering insights into their essential role in

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UN tax committee to update to key transfer pricing manual for developing countries

By Julie Martin, Editor, MNE Tax The next edition of the United Nations Practical Manual on Transfer Pricing for Developing Countries will include a new chapter on financial transactions, substantial revisions current guidance on the transactional profit-split methodThe Profit-Split Method (PSM) is a critical tool in transfer pricing, used to allocate profits or losses among associated enterprises participating in

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S.Africa: Revenue Service issues interpretation note on headquarter companies

South Africa Report from our correspondent Lutando Mvovo, South Africa Revenue ServiceTax authorities are fundamental institutions within government frameworks, overseeing tax assessment, collection, and administration. Their operations ensure that tax laws are enforced and public funds are collected efficiently. This article delves into tax authorities’ purpose, responsibilities, and structure, offering insights into their essential role

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S.Africa: New VAT regulations for electronic services effective April 2019

New VAT regulations for electronic services effective April 2019 Baker McKenzie – Stephan Spamer and Seelan Moonsamy South Africa November 26 2018 The National Treasury recently published an amended Regulation for electronic services, in line with the proposal by the Minister of Finance in Budget Review 2017, that the value added tax (VAT) base for electronic services was to be

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S.Africa: Important judgment on simulation handed down by Supreme Court of Appeal

Important judgment on simulation handed down by Supreme Court of Appeal On 9 November 2018, the South African Supreme Court Appeal (“SCA”) handed down an important judgment in which it upheld Sasol Oil (Pty) Ltd’s appeal against a judgment of the Gauteng Tax Court. The facts of the case were complex, but concerned certain back-to-back

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South Africa’s Revenue Service releases updated guidance on seeking mutual agreement procedure assistance

South Africa’s Revenue Service releases updated guidance on seeking mutual agreement procedure assistance DLA Piper South Africa’s Revenue ServiceTax authorities are fundamental institutions within government frameworks, overseeing tax assessment, collection, and administration. Their operations ensure that tax laws are enforced and public funds are collected efficiently. This article delves into tax authorities’ purpose, responsibilities, and

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