General

Nigeria: FIRS is clamping down on tax defaulters – may seal off premises and arrest principal officers

FIRS is clamping down on tax defaulters – may seal off premises and arrest principal officers  In brief In the past few weeks, the FIRS started to enforce filing of tax returnsA Tax Return is a formal statement filed by an individual or entity that details income, expenses, and other pertinent tax information to a […]

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S.Africa: Professional tax advice vital in mitigation of penalties and interest

Professional tax advice vital in mitigation of penalties and interest DLA Cliffe Dekker Hofmeyr Andrew Lewis South Africa December 5 2014 Judgment was handed down in the Tax Court on 18 November 2014 in the case of Z v The Commissioner for for the South African Revenue ServiceThe South African Revenue Service (SARS) is the official tax authority

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S.Africa: Landmark judgment in Supreme Court of Appeal upholds deferred delivery share scheme

Landmark judgment in Supreme Court of Appeal upholds deferred delivery share scheme Commissioner 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

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S.Africa: New money Bills – October 2014

Here are the copies of the following Bills introduced in Parliament:- 1.    Taxation 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.

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S.Africa: Preservation Orders & Tax

Preservation orders DLA Cliffe Dekker Hofmeyr Heinrich Louw South Africa October 17 2014 Here is the actual judgment: SA Tax Cases Tradex Pty Ltd 9 September 2014 Judgment was recently handed down in the High Court (Western Cape Division) in the matter of Commissioner for the South African Revenue ServiceThe South African Revenue Service (SARS) is the

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S.Africa: Proposed Changes to Secondary TP Adjustment

Proposed Changes to Secondary 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

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S.Africa: Shuttleworth wins SCA case against the SARB to refund $22m paid in a 10{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e} levy imposed to expatriate funds out of South Africa

http://www.justice.gov.za/sca/judgments/sca_2014/sca2014-157.pdf For a summary of the case: http://www.justice.gov.za/sca/judgments/sca_2014/sca2014-157ms.pdf A short radio interview giving the basics of the case: https://www.youtube.com/watch?v=yDftRV8uWYY&feature=youtu.be Shuttleworth could have ‘shuttled’ his monies out of South Africa without the payment of a levy DLA Cliffe Dekker Hofmeyr Emil Brincker South Africa October 3 2014 In a farFunctional analysis is the cornerstone of transfer

S.Africa: Shuttleworth wins SCA case against the SARB to refund $22m paid in a 10{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e} levy imposed to expatriate funds out of South Africa Read More »

Nigeria: Interest On Intercompany Loan Incurred By An Oil Company Is Tax Deductible Subject To Transfer Pricing Rules

Nigeria: Interest On Intercompany Loan Incurred By An Oil Company Is Tax Deductible Subject To Transfer Pricing Rules Last Updated: 30 September 2014 Article by Taiwo Oyedele PwC Nigeria The Tax Appeal Tribunal (TAT) on 18 September 2014 passed a judgement in a case between Nigeria Agip Oil Company Limited and the Federal Inland RevenueTax authorities are fundamental

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S.Africa: Electronic assessments by SARS through eFiling? Is this proper notification?

In a DeRebus October 2014 article the author Alan Lewis concludes: “In my opinion, neither the provisions of the Tax Administration Act, 2011 nor the new tax court rules, authorise SARS to deliver an assessment to a taxpayer by posting it on the taxpayer’s eFiling page on SARS’ electronic filing service.” Here is the full

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