General Archives - Page 17 of 49

3M Company v Commissioner of Internal Revenue: U.S. Transfer Pricing and Foreign Legal Restrictions

FP News, Postgraduate Programmes in International Tax, Postgraduate Programmes in Transfer Pricing, Tax Dispute Resolution, TP Case Summaries, Transfer Pricing, United States / Dr Daniel N Erasmus

The dispute focused on 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 source of revenue for governments and funds various public expenditures, such as infrastructure projects, healthcare, education, national security, and welfare programs. The tax is generally calculated as a percentage of the taxable... More treatment of intellectual propertyIntellectual Property (IP) refers to creations of the mind, including inventions, literary and artistic works, symbols, names, images, and designs used in commerce. It grants creators exclusive legal rights to use and exploit their work, ensuring protection against unauthorised use or reproduction. These rights are critical in fostering innovation and creativity while providing economic value to individuals and organisations. IP... More (IPIntellectual Property (IP) refers to creations of the mind, including inventions, literary and artistic works, symbols, names, images, and designs used in commerce. It grants creators exclusive legal rights to use and exploit their work, ensuring protection against unauthorised use or reproduction. These rights are critical in fostering innovation and creativity while providing economic value to individuals and organisations. IP... More) transactions between 3M’s U.S. subsidiaries and its Brazilian subsidiary, 3M do Brasil Ltda (3M Brazil), for the tax year 2006.

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Nokia vs. India: Permanent Establishment and Profit Attribution Dispute

FP News, India, International, International Tax, Permanent Establishment, Postgraduate Programmes in International Tax, Postgraduate Programmes in Transfer Pricing, Tax Dispute Resolution, TP Case Summaries, Transfer Pricing / Dr Daniel N Erasmus

The case revolved around whether Nokia Solutions and Networks Oy had a Permanent Establishment (PE) in India, and whether profits could be attributed to that PE under the India-Finland Double TaxationDouble Taxation occurs when the same income or financial transaction is taxed twice, typically in different jurisdictions. It can arise in two primary contexts: economic double taxation, where the same income is taxed twice in the hands of different taxpayers, and juridical double taxation, where the same taxpayer is taxed on the same income in more than one country. Double... More Avoidance Agreement (DTAA).

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Fiat Chrysler Finance Europe and Ireland v Luxembourg: State Aid, Transfer Pricing, and the Arm’s Length Principle

Arms Length Principle, EU, FP News, International, Luxembourg, Postgraduate Programmes in Transfer Pricing, Tax Dispute Resolution, TP Case Summaries / ATL-Editor

The case involves two appeals by Fiat Chrysler Finance Europe (formerly Fiat Finance and Trade Ltd) and Ireland, challenging the General Court’s decision to uphold a European Commission ruling that a tax rulingA tax ruling is a formal decision provided by a tax authority, clarifying how specific tax laws and regulations apply to an individual taxpayer or a corporate entity in particular circumstances. Often sought before a significant financial transaction or investment, tax rulings offer legal certainty by outlining the tax implications and obligations in advance. Such rulings are pivotal for multinational... More granted by Luxembourg to Fiat Chrysler Finance Europe constituted unlawful state aidState Aid refers to financial assistance provided by public bodies, typically governments, which can selectively benefit certain businesses or industries. This concept is critical in European Union (EU) law, where such support can distort competition and trade within the single market. State Aid, regulated under EU law, aims to ensure fair competition and prevent Member States from favouring local businesses... More.

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Protected: SAIT TP Summit I/I/T/F Document Download

South Africa / ATL-Editor

There is no excerpt because this is a protected post.

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TANZANIA: Licensing of Tax Consultants – A clog/fetter to taxpayer’s right to representation?

Tanzania / ATL-Editor

Published by: B&E Ako Law Taxpayers are now required to be represented by licensed tax consultantsA Tax AdvisorA 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 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 lawsTax 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 and ensuring compliance with the latest regulations while identifying

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SOUTH AFRICA: Think Tax compliance is simple? Think again (PART 2)

South Africa / ATL-Editor

The article was written and published by: ReganVanRooy 10 common mistakes in SA 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

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SOUTH AFRICA: Replacement of IT14SD forms – New SARS Verification Process

South Africa / ATL-Editor

AUTHOR: Ziyaad Moosa – PKF Octagon (Johannesburg) With effect from 16 September 2022, The South African Revenue Services (SARSThe 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 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 (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) is the official tax authorityTax 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 responsible for the administration and enforcement of tax lawsTax 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. It plays a crucial role in managing the country’s fiscal policy by collecting revenue,

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NIGERIA: VAT and the Reverse Charge Mechanism in Nigeria

Nigeria / ATL-Editor

Article by: Abdulateef Olatunji ABDULRAZAQ (Founder, Taxmobile.Online) Introduction Value Added Tax (VAT) is a consumption tax imposed on the value of the supply of taxable goods and services produced and consumed in Nigeria. The Finance Act (FA)2020 generally defines taxable supplies of goods and services as supplies received and consumed by a person in Nigeria,

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Mozambique – Mandatory Social Security Pardon of Fines and Reduction of Interests

SADC / ATL-Editor

Decree No. 42/2022, of 17 August, was recently approved, adopting measures to ensure support to employer entities and self-employed individuals in Cabo Delgado Province affected by terrorism. Click here to download the full document.

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Think Tax compliance is simple? Think again

Africa, South Africa / ATL-Editor

Article was written and published by: ReganVanRooy 10 common mistakes in SA 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

Think Tax compliance is simple? Think again Read More »