Tax Dispute Resolution Archives - Page 9 of 13

Join Us at the GTC Conference 2024 in Milan: Mastering Controversy Roadmaps for MNEs

Dispute Resolution, International, International Tax, Tax Dispute Resolution, Transfer Pricing / Dr Daniel N Erasmus

Discover strategies at the GTC Conference 2024 on creating a controversy roadmap for MNEsWhat 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 customer bases across borders. The fundamental aspect that distinguishes MNEs from other corporate forms is their cross-border activity, which can include... More. Join us in Milan or online on June 7, 2024.

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WORKSHOP: Conducting a Transfer Pricing Trial

International Tax, Tax Dispute Resolution, Transfer Pricing / Dr Daniel N Erasmus

Join our free workshop on 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 property) are set when these items are exchanged between different branches, subsidiaries, or affiliates of... More trials led by Prof Dr Daniel N Erasmus. Gain insights and strategies for managing royalty rate disputes.

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Tax Dispute Resolutions: A Case Study on Tresping Manufacturing vs. SARS

Dispute Resolution, South Africa, Tax Dispute Resolution / Dr Daniel N Erasmus

Explore the critical insights from the Tresping Manufacturing vs. SARSThe 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 fiscal policy by collecting revenue, administering customs, and ensuring compliance with tax legislation. Established under the South African Revenue Service Act, No. 34 of 1997, SARS functions independently... More case on navigating tax disputesTax Disputes arise when there is a disagreement between taxpayers and tax authorities regarding the interpretation or application of tax laws. These disputes may concern various issues such as the accuracy of a tax return, the eligibility for tax deductions or credits, the correct amount of tax liability, or transfer pricing adjustments. Tax disputes can lead to lengthy legal proceedings... More and compliance with customs regulations.

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Landmark Transfer Pricing Case from South Africa

International, International Tax, South Africa, Tax Dispute Resolution, Transfer Pricing / Dr Daniel N Erasmus

TRM Tax Attorneys secures landmark victory in South Africa’s first 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 property) are set when these items are exchanged between different branches, subsidiaries, or affiliates of... More case, demonstrating expertise in resolving complex tax disputesTax Disputes arise when there is a disagreement between taxpayers and tax authorities regarding the interpretation or application of tax laws. These disputes may concern various issues such as the accuracy of a tax return, the eligibility for tax deductions or credits, the correct amount of tax liability, or transfer pricing adjustments. Tax disputes can lead to lengthy legal proceedings... More. Learn how Prof Dr Daniel N Erasmus and his team can assist you.

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X BV v Netherlands (Staatssecretaris van Financiën Case)

EU, FP News, International, Netherlands, OECD, Tax Dispute Resolution, TP Case Summaries, Transfer Pricing / Dr Daniel N Erasmus

The X BV v Staatssecretaris van Financiën case revolves around a key issue in corporate taxCorporate Tax refers to the tax imposed by governments on the income or capital of corporations. Corporations, considered separate legal entities, are taxed on their profits, meaning the income generated from their operational activities, investments, and other financial undertakings. This tax is generally a key revenue source for governments, helping to fund public services, infrastructure, and other essential functions. The... More: the denial of interest deductions for intra-group loans in cross-border transactionsIntra-Group Transactions are interactions between entities within the same multinational enterprise (MNE). Such transactions form the backbone of related-party dealings and are essential in managing global operations and aligning business objectives across jurisdictions. Understanding intra-group transactions is critical in international tax and transfer pricing, as they directly impact a company's tax obligations, profitability, and compliance standing. Tax professionals, accountants, lawyers,... More.

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South Africa’s First Transfer Pricing Case

International, International Tax, South Africa, Tax Dispute Resolution, Transfer Pricing / Dr Daniel N Erasmus

Explore how TRM’s expertise in 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 property) are set when these items are exchanged between different branches, subsidiaries, or affiliates of... More challenges in South Africa helped ABD Limited win against SARSThe 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 fiscal policy by collecting revenue, administering customs, and ensuring compliance with tax legislation. Established under the South African Revenue Service Act, No. 34 of 1997, SARS functions independently... More, offering insights for multinationals.

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South Africa’s first Transfer Pricing case, and it’s a win for the taxpayer!

International, South Africa, Tax Dispute Resolution, Transfer Pricing / Dr Daniel N Erasmus

Can we hear a “woohoo”!? Yes, you read right, South Africa has finally had its first TP case and whaddaya know, the taxpayer won!

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ABD Limited vs. SARS Transfer Pricing Dispute Judgment

Africa, International, South Africa, Tax Dispute Resolution, Transfer Pricing / Dr Daniel N Erasmus

Explore the critical analysis of the transfer pricing dispute judgment between ABD Limited and SARS, focusing on IP royalties and tax implications.

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DID YOU MISS THE MASTERING TAX DISPUTE RESOLUTION IN SOUTH AFRICA WORKSHOP?

Dispute Resolution, South Africa, Tax Dispute Resolution / Dr Daniel N Erasmus

This workshop was designed to give aspiring and practising tax professionals an overview of what is needed to navigate the complex terrain of tax audits, assessments, objections, appeals, tax boardTax 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 supporting government functions and economic stability. What is a Tax Authority? A tax authority is... More hearings, and emerging developments in tax legislationTax laws form the backbone of any nation’s revenue system, setting the rules that govern how individuals and corporations contribute financially to support government functions. These laws define the types of taxes, the applicable rates, and the regulations regarding payment and compliance. They also outline the rights and obligations of taxpayers, ensuring a balanced and fair approach to funding public... More in South Africa.

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Article 26 of the OECD Model Tax Convention Update 2024

Dispute Resolution, International, International Tax, Tax Dispute Resolution / Dr Daniel N Erasmus

The recent approval by the OECD Council of the OECD Model Tax Convention Update 2024 marks a pivotal moment for international tax practitionersA Tax Advisor is a professional who provides specialised advice to individuals, businesses, and organisations on various tax-related matters. They play a crucial role in guiding clients through complex tax laws and ensuring compliance with the latest regulations while identifying opportunities for tax efficiency. Tax Advisors must stay updated on legislative changes and understand the impact of international tax treaties,... More and multinational organizationsWhat 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 customer bases across borders. The fundamental aspect that distinguishes MNEs from other corporate forms is their cross-border activity, which can include... More

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