SADC

Lecture 6 – https://www.dropbox.com/s/i9lflc95le5dvtt/U2655921R32125S2155057266.el8?dl=0 Lecture 7 – https://www.dropbox.com/s/qqo2nl705ns6ewj/U2660565R32125S2592226059.el8?dl=0 Follow curriculum – Reading: International Tax Primer 3rd Edition Brian Arnold – eBook – Chapter 2 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 is to promote policies that improve... More Income and Capital Model Convention and Commentary 2017 ARTICLES 4, 5 and 7, then 14 to 20 and 28, and commentaries UN Model Double TaxationDouble Taxation occurs when the same income or financial transaction is taxed twice, typically in different jurisdictions. It can arise in two primary contexts: economic double taxation, where the same income is taxed twice in the hands of different taxpayers, and juridical double taxation, where the same taxpayer is taxed on the same income in more than one country. Double... More Convention and Commentaries 2011 Update ARTICLES 4, 5 and 7, then […]

Lecture 2: IT Lecture 2 summary of principles of international tax IT course 2018 Lecture 2 slide notes Unfortunately there was a problem with the Electa Live recording. Listen to this practical lecture on international tax and its application to transfer pricingTransfer pricing is a fundamental concept in international taxationFOR MORE INSIGHT ON INTERNATIONAL TAXATION, PLEASE READ THIS ARTICLE: Introduction to International Taxation: Key Concepts & Guidelines International Taxation encompasses the framework of laws, principles, and treaties that govern the tax obligations of individuals and entities engaged in economic activities that span multiple jurisdictions. This field addresses how income, profits, and gains are taxed when operations or investments extend... More that defines the pricing methods

Actual recorded lecture – https://www.dropbox.com/s/uhomap01aaoehjv/Lecture{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}201{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20-{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20IT{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Intro{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}26{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20overview.mp4?dl=0 Also on YOU TUBE: https://www.youtube.com/watch?v=osqpnK2vSkc   SEE summary of lecture below: see the new curriculum here: http://iitfconnect.com/?p=1327 – containing details of the course/lecture dates, assignments and tutorials, with links to all the reading materials required. INDEX TO ALL course reading materials per LECTURE, with hyperlinks to download: New IT Course Web Addresses Index Lecture 1 presentation slides: IT

Pre-recorded lecture: Dispute Resolution: https://www.dropbox.com/sh/9own8vamz4i6y6b/AABsDBeP1ZOiOf97UCF5po8ea?dl=0 TP 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 is to promote policies that improve... More Draft-Handbook-TP-Risk-Assessment-ENG Follow curriculum – Reading: 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 is to promote policies that improve... More TPG 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 items are exchanged between different branches, subsidiaries, or affiliates of... More Guidelines for Multinational EnterprisesWhat are Multinational Enterprises (MNEs)? Multinational Enterprises, commonly referred to as MNEs, are corporations that operate in multiple countries through various subsidiaries, branches, or affiliates. These entities maintain a central management structure while leveraging diverse resources, labour markets, and customer bases across borders. The fundamental aspect that distinguishes MNEs from other corporate forms is their cross-border activity, which can include... More and 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 into their essential role in supporting government functions and economic stability. What is a Tax Authority? A tax authority is... More July 2017 Chapter IV: Parts C, D, F, G BEPSBEPS stands for “Base Erosion and Profit Shifting”. BEPS refers to tax avoidanceTax avoidance refers to the practice of legally structuring financial activities to minimise tax liability, reducing the amount of tax owed without violating laws. Unlike tax evasion, which is illegal and involves concealing income or misreporting, tax avoidance operates within the framework of the law. Multinational enterprises (MNEs) and individuals often engage in tax planning strategies that reduce tax liabilities... More strategies used by multinational enterprisesWhat are Multinational Enterprises (MNEs)? Multinational Enterprises, commonly referred to as MNEs, are corporations that operate in multiple countries through various subsidiaries, branches, or affiliates. These entities maintain a central management structure while leveraging diverse resources, labour markets, and customer bases across borders. The fundamental aspect that distinguishes MNEs from other corporate forms is their cross-border activity, which can include... More (MNEsWhat are Multinational Enterprises (MNEs)? Multinational Enterprises, commonly referred to as MNEs, are corporations that operate in multiple countries through various subsidiaries, branches, or affiliates. These entities maintain a central management structure while leveraging diverse resources, labour markets, and customer bases across borders. The fundamental aspect that distinguishes MNEs from other corporate forms is their cross-border activity, which can include... More) to exploit gaps and mismatches in the

FINAL EXAM LECTURE … listen, make notes and pay attention to the pre-recorded lectures below and the references in the accompanying slide: https://www.dropbox.com/sh/jn99bjfyumumf5m/AACw7JdSHVZpP0ejxMxBhbw4a?dl=0 Intro to TP with updates: www.africataxjournal.com/?p=1463 Pre-recorded preparation lectures for the lecture ABOVE: Compliance Part I : https://www.dropbox.com/sh/96qw8dl8gzt5ooa/AAAbeZQjNb2vFKr0m2SQmiiMa?dl=0 Case Study referred to: lecture DISPUTES 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 items are exchanged between different branches, subsidiaries, or affiliates of... More and dispute resolution chapter 17 case study

Follow curriculum – Reading:   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 is to promote policies that improve... More Income and Capital Model Convention and Commentary 2017 Article 7 and the commentaries on Permanent Establishments   BEPSBEPS stands for "Base Erosion and Profit Shifting". BEPS refers to tax avoidance strategies used by multinational enterprises (MNEs) to exploit gaps and mismatches in the international tax system. By shifting profits from high-tax jurisdictions to low- or no-tax locations, MNEs reduce their overall tax burden, even if little to no economic activity occurs in the low-tax jurisdictions. These practices erode... More Action 7 – PEs http://www.oecd.org/ctp/beps-actions.htm General ongoing reading as the courses advance, reading about 10 pages a week to gain an overview understanding: An Overview of 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 items are exchanged between different branches, subsidiaries, or affiliates of... More by IBFD    

Follow curriculum – Reading: 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 is to promote policies that improve... More TPG 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 items are exchanged between different branches, subsidiaries, or affiliates of... More Guidelines for Multinational EnterprisesWhat are Multinational Enterprises (MNEs)? Multinational Enterprises, commonly referred to as MNEs, are corporations that operate in multiple countries through various subsidiaries, branches, or affiliates. These entities maintain a central management structure while leveraging diverse resources, labour markets, and customer bases across borders. The fundamental aspect that distinguishes MNEs from other corporate forms is their cross-border activity, which can include... More and 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 into their essential role in supporting government functions and economic stability. What is a Tax Authority? A tax authority is... More July 2017 Chapter IX 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 items are exchanged between different branches, subsidiaries, or affiliates of... More & Business Restructuring by IBFD General ongoing reading as the courses advance, reading about 10 pages a week to gain an overview understanding: An Overview of 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 items are exchanged between different branches, subsidiaries, or affiliates of... More by IBFD    

Follow curriculum – Reading: OECD TPG Transfer Pricing Guidelines for Multinational Enterprises and Tax Administration July 2017 Chapter VIII BEPS Action 8-10 Cost contribution arrangements, pages 161-177 BEPSBEPS stands for “Base Erosion and Profit Shifting”. BEPS refers to tax avoidanceTax avoidance refers to the practice of legally structuring financial activities to minimise tax liability, reducing the amount of tax owed without violating laws. Unlike tax evasion, which is illegal and involves concealing income or misreporting, tax avoidance operates within the framework of the law. Multinational enterprises (MNEs) and individuals often engage in tax planning strategies that reduce tax liabilities... More strategies used by multinational enterprisesWhat are Multinational Enterprises (MNEs)? Multinational Enterprises, commonly referred to as MNEs, are corporations that operate in multiple countries through various subsidiaries, branches, or affiliates. These entities maintain a central management structure while leveraging diverse resources, labour markets, and customer bases across borders. The fundamental aspect that distinguishes MNEs from other corporate forms is their cross-border activity, which can include... More (MNEsWhat are Multinational Enterprises (MNEs)? Multinational Enterprises, commonly referred to as MNEs, are corporations that operate in multiple countries through various subsidiaries, branches, or affiliates. These entities maintain a central management structure while leveraging diverse resources, labour markets, and customer bases across borders. The fundamental aspect that distinguishes MNEs from other corporate forms is their cross-border activity, which can include... More) to exploit gaps and mismatches in the international tax system. By shifting profits

Follow curriculum – Reading: OECD TPG Transfer Pricing Guidelines for Multinational Enterprises and Tax Administration July 2017 Chapter VIII BEPS Action 8-10 Cost contribution arrangements, pages 161-177 BEPS Actions 8-10 Final Report Intangibles, Risks & Capital, High-Risk Transactions http://www.oecd.org/ctp/beps-actions.htm General ongoing reading as the courses advance, reading about 10 pages a week to gain an overview understanding: An Overview of Transfer

Follow curriculum – Reading: OECD TPG Transfer Pricing Guidelines for Multinational Enterprises and Tax Administration July 2017 Chapter VIII BEPS Action 8-10 Cost contribution arrangements, pages 161-177 BEPS Actions 8-10 Final Report Intangibles, Risks & Capital, High-Risk Transactions http://www.oecd.org/ctp/beps-actions.htm General ongoing reading as the courses advance, reading about 10 pages a week to gain an overview understanding: An Overview of Transfer