General

Double Tax Treaties: An Introduction

Africa, Asia, Europe, North America, Oceania, OECD, South America /

Paper by: Reuven S. Avi-Yonah The existing network of over 2,500 bilateral double tax treaties (DTTs) represents an important part of international law. The current DTTs are all based on two models, the OECDThe Organisation for Economic Co-operation and Development (OECD) is an international organisation comprising 38 member countries, established to foster economic growth, trade, […]

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ANTI-AVOIDANCE MEASURES OF GENERAL NATURE AND SCOPE-GAAR AND OTHER RULES

Argentina, South America /

Paper by: Guillermo O. Teijeiro  Most countries have either judicial or statutory general anti-avoidance rules (GAAR); Argentina enrols in the second group as GAAR are of statutory nature. Countries in both groups frequently combine GAAR with special anti-avoidance rules (SAAR).  GAAR are generally applied to interpret tax rules, to characterize taxpayers acts and transactions (i.e.,

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THE UTILITY OF ADVANCE PRICING AGREEMENTS (APAs)

Nigeria, West Africa /

Paper by: Olamide Akinla Nigeria introduced 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

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OECD – Revenue Statistics 2019

OECD /

This annual publication presents a unique set of detailed and internationally comparable tax data in a common format for all OECDThe Organisation for Economic Co-operation and Development (OECD) is an international organisation comprising 38 member countries, established to foster economic growth, trade, and development on a global scale. Founded in 1961, the OECD provides a

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Tax Controversy – Impact Of ‘Disruptive’ Digitalization Processes on Taxpayers

EU, Europe /

In a world that is moving at a fast pace in the light of the “disruptive” digitalization processes happening at the moment, it is essential for taxpayers to be aware of their rights and of the balance of power existing between them and the tax authorities (“TAs”).  In this webinar we will discuss rulings from the

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NIGERIA – Tax Appeal Tribunal delivers landmark decision on threshold for exported service under Nigerian tax law – Ken Etim, Abimbola Akeredolu, Azeezah Muse-Sadiq, Kemi Ajayi , Oluwatoba Oguntuase and Emmanuel Onyeabor (Banwo & Ighodalo)

FP News, Nigeria, West Africa /

The Tax Appeal Tribunal, Lagos Zone (“TAT” or the “Tribunal”), recently held thatservices which flow from service providers in Nigeria to third parties (such as, persons resident in Nigeria) on behalf of or for the benefit of persons resident outside Nigeria do not constitute exported service for tax purposes in Nigeria. It also held that

NIGERIA – Tax Appeal Tribunal delivers landmark decision on threshold for exported service under Nigerian tax law – Ken Etim, Abimbola Akeredolu, Azeezah Muse-Sadiq, Kemi Ajayi , Oluwatoba Oguntuase and Emmanuel Onyeabor (Banwo & Ighodalo) Read More »

SOUTH AFRICA – Tax revenues from the digital economy – Peter Dachs (ENSAfrica)

Africa, FP News, SADC, South Africa /

International tax lawTax 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

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PARAGUAY – “Tax treaty overrides: tension between Paraguayan Constitutional Law and the Vienna Convention on the Law of Treaties. An economic and legal analysis of the feasibility of implementing Double Taxation Treaties with uncertain reciprocity” – Lui Carísimo

FP News, South America /

DTC are binding agreements between usually two States and thus are governed by Public International Law. In the majority of jurisdictions, the introduction of DTC into domestic legislation is required for having binding effects. Paraguay follows this legal principle, where ratified treaties are above national law – but below the Constitution – upon exchange of

PARAGUAY – “Tax treaty overrides: tension between Paraguayan Constitutional Law and the Vienna Convention on the Law of Treaties. An economic and legal analysis of the feasibility of implementing Double Taxation Treaties with uncertain reciprocity” – Lui Carísimo Read More »

ETHIOPIA – Revisiting Ethiopian Income Tax law on Tax Evasion and Avoidance: Special emphasis on Share Companies – MUSTEFA ALI MOHAMMED

East Africa, FP News /

The one that should have to be in the problem is the one that is included in the spectrum of being good to those around him that the person goes in the way that will ultimately contribute to the on that enhance to the best of the person that will entitled to those that are

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SOUTH AFRICA – The Taxation of International (non-resident) Sportspersons in South Africa – Craig West

Africa, FP News, SADC, South Africa /

A critical analysis of the relevance of the OECDThe Organisation for Economic Co-operation and Development (OECD) is an international organisation comprising 38 member countries, established to foster economic growth, trade, and development on a global scale. Founded in 1961, the OECD provides a forum for governments to collaborate, share policy experiences, and develop solutions to

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