Africa

OECD: Seven BEPS Actions issued September 16, 2014

COMMENT BY DR. D.N. ERASMUS – This is a summary of an article first published in a Bloomberg BNA 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 […]

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S.Africa: Proposed changes to secondary transfer pricing adjustment

DLA Cliffe Dekker Hofmeyr Heinrich Louw South Africa September 12 2014 National Treasury and the 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,

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OECD: First recommendations for combating international tax avoidance by multinational enterprises on Tuesday 16 September 2014

http://www.oecd.org/tax/oecd-to-release-first-recommendations-for-combating-international-tax-avoidance-by-multinational-enterprises-on-tuesday-16-september-2014.htm 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 core mission

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S.AFRICA: Expenditure relating to deferred accruals

Expenditure relating to deferred accruals DLA Cliffe Dekker Hofmeyr Heinrich Louw South Africa September 5 2014 Background The taxpayer operated a mine. Firstly, it would extract mineral ore from the earth, and secondly, by smelting and other processes, it would extract a concentrate (containing the minerals) from the ore. The taxpayer sold the concentrate to

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S.AFRICA: Recent tax case – Fringe benefits planning ‘faux pas’ on a company car & other benefits – or not?

S.AFRICA: Recent tax case – Fringe benefits planning ‘faux pas’ on a company car & other benefits – or not?     In a Gauteng Tax Court judgment, the judge found the only taxpayer witness (who designed the salary sacrifice scheme) not to be credible. In essence a notional account in the taxpayer company was created

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S.AFRICA: Documentation in tax disputes highlighted in the New dispute resolution rules

Article by Stephen Levetan and Taryn Solomon ENSafrica The new rules promulgated under section 103 of the Tax AdministrationTax 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

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S.AFRICA: Collection & exchange of tax related information by tax authorities

Article by Mathabo Magolego ENSafrica Tax authorities across the globe are working aggressively to collect taxes which they believe are collectable in their respective jurisdictions. States are entering into bilateral and multilateral agreements aimed at assisting each other in the collection of information and taxes. South Africa has actively taken part and in some respects been a regional leader in issues relating

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S.AFRICA: Huang & Mpisi Trading 74 (Pty) Ltd – Search & Seizure Warrants under Tax Administration Act, 2011

Here is the full judgment: SA Tax Court search seizure review less intrusive Huang and Others Including Mpisi Trading 74 Pty Ltd 13 August 2014 I’m sure there is a chance it will go to the SCA with these legal expenses incurred. Take aways – from this judgment, SARSThe South African Revenue Service (SARS) is

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ANGOLA: New Transfer Pricing Rules in Angola: What Do They Mean?

Within tax reform currently underway in Angola, a new 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

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INDIA: Taxability of overseas share sale – India influences African Tax Administrations

Since the 2012 Union Budget specified that shares of a foreign company would be deemed to be situated in India if it derives its value “substantially” from assets located in India, there has been uncertainty over what this really means. A recent case clarifies the matter. Delhi High Court clarifies taxability of overseas share sale

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