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TP Lecture week 1 – TP Legal Framework

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General background summary reading for a FULL overview of TP, in this order, which should be your ongoing reading during this course: 6 Chapter 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 B Arnold International Tax Primer 3rd ed 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 PWC International TP 2015-16 up to page 182 Follow the curriculum – Reading for the lecture: 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 […]

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TP judgments in Africa – as at Nov 2019

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Here is a list of the current cases: The first Ghana TP case – TP Ghana JUDGMENT IN TAX APPEAL CASE BETWEEN BIERSDORF GH LTD AND THE COMM GENERA… The first RSA TP related case – Crookes Brothers Ltd v Commissioner for 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, administering customs, and ensuring compliance with tax legislation. Established under the South African Revenue Service Act, No. 34 of 1997, SARS functions independently... More [2018] ZAGPHC 311 (judgment delivered 8 May 2018) This is a

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Tax risk management free pdf book

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by Dr Daniel N Erasmus PhD EA USTCP Int’l Tax Attorney Tax RiskTax Risk refers to the uncertainty surrounding the potential financial or reputational impact of tax-related decisions and events on a business or individual. This risk arises due to various factors, such as complex tax regulations, inconsistent tax authority interpretations, or evolving international tax laws. Effective tax risk management involves identifying, assessing, and mitigating potential tax-related threats to prevent financial penalties,... More ManagementTax risk management is a structured process used by organizations, particularly 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 identify, assess, and mitigate potential risks that arise in relation to tax complianceTax Compliance refers to the adherence of individuals and businesses to the tax laws and regulations of a specific jurisdiction. It encompasses the timely and accurate filing of tax returns, the payment of tax liabilities, and ensuring that all tax-related obligations are met as stipulated by legislation. Compliance involves more than just submitting tax forms; it includes maintaining accurate financial... More, reporting, and planning. It plays a crucial role in ensuring that a

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Supporting documents to the TP Introduction and Update Seminar

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The Continuing Education Questions are at the bottom of this page. Seminar recordings: Lecture 1 – https://www.dropbox.com/s/qhufher4kxqchxb/1st{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}202018-07-25{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}2014.30{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Transfer{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Pricing{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20-{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Introduction{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Course{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20by{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Dr{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Daniel{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Erasmus.mp4?dl=0 The first part of the first lecture by Prof. Dr. Erasmus was not clear due to connectivity issues. That first part is clearly recorded above. alternate link: https://www.dropbox.com/s/0ucej5b6kjhicp8/2018-07-25{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}2014.30{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Transfer{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Pricing{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20-{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Introduction{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Course{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20by{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Dr{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Daniel{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Erasmus.wmv?dl=0 Lecture 2 – https://www.dropbox.com/s/5jsd2z3dmqkilat/2nd{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}202018-07-26{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}2014.31{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Transfer{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Pricing{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20-{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Introduction{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Course{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20by{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Dr{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Daniel{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Erasmus.mp4?dl=0 alternate link: https://www.dropbox.com/s/xeqj6udkgep8r7t/2018-07-26{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}2014.31{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Transfer{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Pricing{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20-{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Introduction{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Course{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20by{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Dr{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Daniel{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Erasmus.mp4?dl=0 Lecture 3 – https://www.dropbox.com/s/bv4uj60idtj1nlo/3rd{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}202018-07-27{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}2014.30{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Transfer{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Pricing{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20-{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Introduction{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Course{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20by{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Dr{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Daniel{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Erasmus.mp4?dl=0 alternate link: https://www.dropbox.com/s/5fib6anelg6241w/2018-07-27{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}2014.31{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Transfer{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Pricing{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20-{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Introduction{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Course{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20by{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Dr{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Daniel{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Erasmus.mp4?dl=0 Updated and

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The IFA MAURITIUS 13th ASIA/AFRICA CONFERENCE 2019

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POEM Panel notes: http://iitfconnect.com/wp-content/uploads/2019/05/Poem-Panel-IFA-Mauritius-2019.pptx POEM notes: http://iitfconnect.com/wp-content/uploads/2019/05/§-14.42-Place-of-effective-management.pdf

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A creature of statute: A decision about the Tax Court’s power to increase understatement penalties – Cliffe Dekker Hofmeyr

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In the recent judgment of Purlish Holdings (Proprietary) Limited v The Commissioner for the South African Revenue ServiceThe 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, administering customs, and ensuring compliance with tax legislation. Established under the South African Revenue Service Act, No. 34 of 1997, SARS functions independently... More (SARS) is the official tax authority responsible for the administration and enforcement of tax 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. They also outline the rights and obligations of taxpayers, ensuring a balanced and fair approach to funding public... More in South Africa. It plays a crucial role in managing the country’s fiscal policy by collecting revenue, administering

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S.Africa: Your taxpayer rights – Tax Dispute Resolution principles

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https://www.linkedin.com/feed/update/urn:li:activity:6511218979674169344/

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SSRN Research Papers download – Tax Planning and other Papers to download

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SSRN Research Papers Congratulations Dr Daniel N Erasmus You are currently in the top 10{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e} of Authors on SSRN by all-time downloads. Check out your Research Papers on SSRN. https://papers.ssrn.com/sol3/cf_dev/AbsByAuth.cfm?per_id=990830 1. Tax PlanningTax planning is the process of organising and structuring one’s financial affairs in a manner that legally minimises tax liabilities while ensuring compliance with relevant tax laws. The primary objective of tax planning is to reduce the amount of taxes paid, optimise the use of available tax benefits, and preserve wealth. It can be applied at various levels, including personal... More as Part of a Tax Risk ManagementTax risk management is a structured process used by organizations, particularly multinational enterprises (MNEs), to identify, assess, and mitigate potential risks that arise in relation to tax compliance, reporting, and planning. It plays a crucial role in ensuring that a company’s tax obligations are managed in a way that minimizes risk exposure while maximizing efficiency and strategic value. More ProcessThomas Jefferson School of Law Research Paper No. 1482423Number of pages: 88 Posted: 04 Oct 2009 Last Revised:

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S.Africa: Win for the employer: Judgment on the Employment Tax Incentive Act

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By CDH Cliffe Dekker Hofmeyr – Louis Botha and Louise Kotze In the recent case of ABC (Pty) Ltd v The Commissioner for the South African Revenue ServiceThe 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, administering customs, and ensuring compliance with tax legislation. Established under the South African Revenue Service Act, No. 34 of 1997, SARS functions independently... More (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 of 1997, SARS functions independently... More) is the official tax authority responsible for the administration and enforcement of tax 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. They also outline the rights and obligations of taxpayers, ensuring a balanced and fair approach to funding public... More in South Africa. It plays a crucial role in managing the country’s

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S.Africa: When must a reportable arrangement be disclosed to SARS?

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By Ben Strauss, Cliffe Dekker Hofmeyr Attorneys Under the Tax AdministrationTax authorities are fundamental institutions within government frameworks, overseeing tax assessmentA tax assessment is a formal determination made by a tax authority to calculate the amount of tax an individual or entity owes. It is a comprehensive evaluation based on financial records, declared income, expenses, deductions, and any applicable tax laws or regulations. Tax assessments may arise from routine self-assessments by taxpayers, or they may be conducted by revenue authorities... More, collection, and administration. Their operations ensure that tax 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. They also outline the rights and obligations of taxpayers, ensuring a balanced and fair approach to funding public... More 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

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