FP News

TP Lecture week 4 – Legal Framework

Listen to the following intro to TP and TP cases (where short summary of lecture is part of the week’stutorial): https://www.dropbox.com/s/q4cpfkv2pa9aoym/ADTP_PreRec_Lecture4_HugoVollebregt.mp4?dl=0 ppt slides from the lecture: https://www.dropbox.com/s/18m582kmk17ohgm/ADTP_PreRec_Lectture4_Slides.pptx?dl=0 For a useful comparative tool on TP country-by-country, look at: https://www.lexology.com/navigator# and select the topic “transfer pricing”   Follow the curriculum – Reading for tutorial summaries this week, in addition to […]

TP Lecture week 4 – Legal Framework Read More »

US TP the pre-trial memorandum in the Coca-cola intangibles case and various articles

Download a copy here: US TP 2018 Coca Cola case petitioner’s pre-trial memorandum To understand the applicable TP principles applicable in the coca-cola case, read this:  US Transfer Pricing and intangibles explained

US TP the pre-trial memorandum in the Coca-cola intangibles case and various articles Read More »

Future expenses deductible now – a judgment about Section 24c of the Income Tax Act

Future expenses deductible now – a judgment about Section 24c of the Income Tax Act Cliffe Dekker Hofmeyr South Africa March 2 2018 Section 24C of the 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

Future expenses deductible now – a judgment about Section 24c of the Income Tax Act Read More »

US: GILTI onerous for non-C corporation CFC shareholders

GILTI rules particularly onerous for non-C corporation CFC shareholders McDermott Will & Emery USA February 9 2018 Summary The recently enacted tax reform legislation significantly expanded the application of Subpart F, including by adding a new inclusion rule for non-routine CFCControlled Foreign Corporations (CFCs) are a fundamental concept in international taxation, referring to foreign companies that

US: GILTI onerous for non-C corporation CFC shareholders Read More »

S.Africa: When to expect a transfer pricing interpretation note?

When to expect a transfer pricing interpretation note? 2018/19 South African National Budget Expectations By Billy Joubert, Deloitte. South African corporate taxpayers have, over the past few years, been subjected to a barrage of additional transfer pricingTransfer pricing is a fundamental concept in international taxation that defines the pricing methods and rules applied to transactions

S.Africa: When to expect a transfer pricing interpretation note? Read More »

S.Africa: Taxpayer wins case against SARS’ failure to issue a Letter of Findings at the conclusion of a tax audit

S.Africa: Taxpayer wins case against SARS’ failure to issue a Letter of Findings at the conclusion of a tax auditA Tax Audit is a comprehensive review or examination conducted by a government’s tax authority. The primary objective of a tax audit is to verify the accuracy of a taxpayer’s financial records, tax returns, and overall

S.Africa: Taxpayer wins case against SARS’ failure to issue a Letter of Findings at the conclusion of a tax audit Read More »

US Tax Reform 2018 – GILTI and “deemed transition tax” for US taxpayer individuals and pass-through LLCs

US 2018 Tax Reform Bill H.R.1 sections 14201 and 14202 on GILTI US 2018 Tax Reform us-tax-reform-context-new-tax-concepts-and-impact-on-your-business-models A US taxpayer, if you own shares in a foreign company of more than 10{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e} – major repercussions are in play now after the latest US tax reform amendments Published on February 1, 2018 Dr Daniel N Erasmus

US Tax Reform 2018 – GILTI and “deemed transition tax” for US taxpayer individuals and pass-through LLCs Read More »