SADC

Canada: TP case – Cameco’s Canada Tax Court Victory Brings Relief for Companies

Canada: Cameco’s Canada Tax Court Victory Brings Relief for Companies • Court rejects government’s arguments of “sham” transactions • Lawyers divided on whether ruling harms 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 […]

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Africa: The Rising Tide of Tax Disputes

The Rising Tide of Tax DisputesTax Disputes arise when there is a disagreement between taxpayers and tax authorities regarding the interpretation or application of tax laws. These disputes may concern various issues such as the accuracy of a tax return, the eligibility for tax deductions or credits, the correct amount of tax liability, or transfer

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GHANA: High Court rules that payment of minimum disputed amount is a prerequisite for filing an appeal

GHANA: High Court rules that payment of minimum disputed amount is a prerequisite for filing an appeal by Renier van Rensburg The Commercial Division of the High Court, in its decision of 13 July 2018, in the case of Beiersdorf Ghana Limited v. The Commissioner General of the Ghana Revenue Authority (CM/TAX/0001/2018), ruled that the payment of

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S.Africa: Cons Court – when can an official (SARS and others) be held personally liable for damages?

Black Sash Trust (Freedom Under Law Intervening) v Minister of Social Development and Others (Corruption Watch (NPC) RF and South African Post Office Soc Limited as Amici Curiae) Case Number: CCT48/17C Citations: [2018] ZACC 36 Judge: Froneman J Judgment Date: 27 September 2018 Case History: This judgment deals with the issue of costs left open

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S.Africa: No tax deduction for damages paid for deliberate breach of supply contract

by Cliffe Dekker Homeyr – Ben Strauss and Jerome Brink South African courts have held, on a number of occasions, that taxpayers are entitled to deduct damages or compensation paid to third parties. However, this principle does not apply in all cases. The case of Kangra Group (Pty) Ltd v Commissioner for SARSThe South African Revenue Service (SARS) is

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TP: Audits – Microsoft, J&J Tax Heads Divulge Tax Feud Strategies

Audits Microsoft, J&J Tax Heads Divulge Tax Feud Strategies Snapshot • Johnson & Johnson uses software tool to keep track of business narrative and audits • Companies should look to the future when assessing risk on tax positions: Microsoft tax counsel By Sony Kassam Microsoft and Johnson & Johnson tax officials say companies must figure out how to

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S.Africa: Mapping out MAP processes – SARS’ new guidelines

On 25 July 2018, the South African Revenue Service (SARS) published its Guide on Mutual Agreement Procedures (Guide) as a general guidance on the Mutual Agreement Procedure (MAP), providing parameters in which competent authorities from the governments of contracting jurisdictions can interact with the intent to resolve international tax disputesTax Disputes arise when there is

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S.Africa: Verifications vs Audits by SARS – is there a difference?

A transcript of a Podcast by Prof. Dr. Daniel N. Erasmus Today I have been asked to talk to you about the question of verification versus audits by the Commissioner in terms of the Tax Administrative Act (TAA) for those of you obviously who are taxpayers, and from time to time, might receive notification from

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US IRS issues first set of GILTI tax regulations

If your entity is owned by a US entity (whole or part) this will affect you and the US holding entity. US IRS issues first set of GILTI tax regulations September 13, 2018 The US IRS today issued its first set of proposed regulations on the global intangible low-taxed income (GILTI) provisions added in the

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OECD update on country-by-country reporting for multinationals

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

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