General Archives - Page 13 of 49

WORKSHOP: Conducting a Transfer Pricing Trial

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.

WORKSHOP: Conducting a Transfer Pricing Trial Read More »

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.

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

Unpacking the Latest EU Transfer Pricing Updates

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

Dive into the latest EU 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 Updates aimed at harmonizing guidelines within the EU, promising clarity and tax certainty for businesses.

Unpacking the Latest EU Transfer Pricing Updates Read More »

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.

Landmark Transfer Pricing Case from South Africa Read More »

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.

X BV v Netherlands (Staatssecretaris van Financiën Case) Read More »

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.

South Africa’s First Transfer Pricing Case Read More »

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!

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

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.

ABD Limited vs. SARS Transfer Pricing Dispute Judgment Read More »

The Journey of a Single Data Point: Cross-Process TP Automation in Workiva

Africa, Europe, International, International Tax, Transfer Pricing / Dr Daniel N Erasmus

As Tax/TP practitioners, we are always looking to build synergies across processes, harmonizing our calculation and reporting flows. Aiming to create a “Single Source of Truth” solution for all our Tax/TP needs. We all feel and understand the pressure we are under to comply with the ever-increasing tax reporting burden. Fragmented, over-engineered, do we need to say more!

The Journey of a Single Data Point: Cross-Process TP Automation in Workiva Read More »

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.

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