Nigeria

TP Lecture week 5 – ALP and introduction to comparability

Follow curriculum – Reading: OECD TPG Transfer Pricing Guidelines for Multinational Enterprises and Tax Administration July 2017 Chapter 1: Section A-C PWC International TP 2015-16 Introduction……………………………………3 Categories of inter-company transfer…..9 The work of the OECD…………………….25 Specific issues in transfer pricing………71 Managing changes to a transfer pricingTransfer pricing is a fundamental concept in international taxation that […]

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TP Lecture week 4 – Legal Framework

Listen to the following intro to TP and TP cases (where short summary of lecture is part of the week’stutorial): https://www.dropbox.com/s/q4cpfkv2pa9aoym/ADTP_PreRec_Lecture4_HugoVollebregt.mp4?dl=0 ppt slides from the lecture: https://www.dropbox.com/s/18m582kmk17ohgm/ADTP_PreRec_Lectture4_Slides.pptx?dl=0 For a useful comparative tool on TP country-by-country, look at: https://www.lexology.com/navigator# and select the topic “transfer pricing”   Follow the curriculum – Reading for tutorial summaries this week, in addition to

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US TP the pre-trial memorandum in the Coca-cola intangibles case and various articles

Download a copy here: US TP 2018 Coca Cola case petitioner’s pre-trial memorandum To understand the applicable TP principles applicable in the coca-cola case, read this:  US Transfer Pricing and intangibles explained

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Tax Intelligence

I wrote a book on tax risk management that includes tax and strategy. It is called TAX INTELLIGENCE and is available on Amazon. https://www.amazon.com/Tax-Intelligence-Habitual-Mistakes-Companies/dp/145006874X However, I am willing to send free pdf copies to those who request it – please send your requests to daniel@TaxRiskManagement.com. I will also send you a summary version. The book has

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Nigeria: Impacts of the OECD BEPS Project on companies operating in Nigeria

Impacts 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 common economic challenges. The OECD’s

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Nigeria: The New Changes At The FIRS And What Taxpayers Should Expect

With the recent appointment of Mr Babatunde Fowler as the acting Executive Chairman of the Federal Inland RevenueTax 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

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Nigeria: PwC secures a favourable judgement on deemed income assessment August 2015

In brief In a recent decision, the Tax Appeal Tribunal (TAT) says a 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

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Africa: S.Africa and other similar jurisdictions – the AUDIT engagement letter

SURVIVING A TAX AUDIT UNDER THE TAX ADMINISTRATION ACT, 2011 Presented by Prof. Dr. D N ERASMUS Tel: 083 458 8422 or +1.561.568.7115 E-mail: daniel@TaxRiskManagement.com www.TaxRiskManagement.com Introduction Viking Pony Africa Pumps (Pty) Ltd t/a Tricom Africa v Hidro-Tech Systems (Pty) Ltd & another 2011 (1) SA 327 (CC) para [37]: …PAJA defines administrative action as

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Nigeria: A Landmark TAT decision in a VAT case on imported services

PwC secures a Landmark TAT decision in a VAT case on imported services In brief On 10 June 2015, the Tax Appeal Tribunal (TAT) sitting in Abuja held that foreign companies providing services outside Nigeria to Nigerian companies are not carrying on business in Nigeria for the purposes of the Nigerian Value Added Tax (VAT).

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