Nigeria

Place of Effective Management: Indian Perspective

Mukesh Butani (BMR Legal) and Ashrita Prasad Kotha (Jindal Global Law School)/August 22, 2018 India introduced the place of effective management (POEM) in its domestic law in Finance Bill of 2015 but due to lack of preparedness it was deferred to April 1, 2017 and made applicable from assessment year 2017-2018. The statement of intent revealed that the purpose […]

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Zambia seeks USD22-million in tax on internet calls

Zambia seeks USD22-million in tax on internet calls Zambia expects to raise USD22-million annually in new tax on internet phone calls. The cabinet approved a 30 ngwee (0.3 kwacha; USD0.03) daily tariff charged on online phone calls. Transport and Communications Minister Brian Mushimba said that the government considered concerns raised by telecom operators. He added

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S.Africa: SARS interpretation note 4 (issue 5): resident: definition in relation to a natural person – physical presence test

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

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TP cases related to TP online course

Australia 2015 Article 9 Chevron Australia Holdings (Pty) Ltd v CoT [2015] FCA 1092 Australia Appeal 2017 Chevron Australia v Comm of Tax [2017 FCAFC 62] Australia Roche Products Pty Ltd (NT 2005_7 & 56-65) Australia-SNF-Australia-Pty-Ltd-v-Commissioner-of-Taxation-2010-FCA-635-25-June-2010 Canada GE Capital [2010 FCA 344] CanLII – 2010 FCA 344 (CanLII) Canada GE Capital [2010 FCA 344] summary

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S.Africa: SARS gets aggressive with tax inquiries

Note by Prof. Dr. Daniel N. Erasmus: We have experience in representing clients at these  inquiries. The 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

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Tax updates Aug 7 in the Africa Tax Journal, incl. the latest July 2018 S.Africa PwC tax case synopsis

https://www.pwc.co.za/en/assets/pdf/synopsis/synopsis-july-2018.pdf?utm_medium=email&utm_source=sharpspring&sslid=MzIxMDA2tjA0NDEzAAA&sseid=MzQzMLM0MjGyNAIA&jobid=d183246e-9a44-4062-9d4f-929180993b19 PwC provides a great summary each month of key tax cases in South Africa. This edition deals with these important  judgments: The SARS discretion with trading stock – Tax Court, in Case No. 13626 (judgment delivered on 18 May 2018), the court was asked to consider whether the adoption of IFRS principles was a

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Looking at it from a S.African perspective: Transfer pricing review and adjustments in the USA

NOTE FROM PROF. DR. DANIEL N. ERASMUS: The key part of the article below is the following, which speaks to the situation in South Africa and TP adjustments. 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

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Malawi tax collector loses TP case against Eastern Produce

Malawi tax collector loses case against Eastern Produce For a copy of the judgment: https://www.dropbox.com/sh/8v1vx14n3hrgky4/AABzcqbi3yExqT14DGRqylDNa?dl=0 BY FESTON MALEKEZO: The High Court in Blantyre has ruled in favour of the multi-national Eastern Produce Limited in a K1.6 billion transfer pricingTransfer pricing is a fundamental concept in international taxation that defines the pricing methods and rules applied to

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Analyzing Value Chains in Business Models Impacted by the Digital Economy

Analyzing Value Chains in Business Models Impacted by the Digital Economy Digitization has given rise to new firms and industries, besides altering the traditional business models and reshaping the global economy. That is a reasonable reason why companies have to evolve the way they conduct a Value Chain Analysis (VCA), in order to be streamlined for digital businesses.

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