SADC

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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Information referred to in a presentation to MNEs

Tax Intelligence book I wrote a book on 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

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S.Africa: SARS new MAP Guide – Final

http://www.sars.gov.za/AllDocs/OpsDocs/Guides/LAPD-IT-G24{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20-{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Guide{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20on{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Mutual{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Agreement{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Procedures.pdf South Africa Report from Prof. Johann Hattingh, University of Cape Town Revenue ServiceTax 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

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S. Africa: CAN THE COURTS MAKE USE OF SARS INTERPRETATION NOTES IN INTERPRETING LEGISLATION?

CAN THE COURTS MAKE USE OF SARS INTERPRETATION NOTES IN INTERPRETING LEGISLATION? 25 Jul 2018 by PKF Durban In the recent case of Marshall N.O. and Others v Commissioner for the South African Revenue Service CCT208/17 [2018] ZACC 11 (25 April 2018), the Constitutional Court was required to consider the late filing of an application for leave

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Various Constitutions and why they are important in tax

SOURCE: of Constitutions of various Countries http://www.wipo.int/wipolex/en/ The above link not only introduces you to various treaties and laws per country on IPIntellectual Property (IP) refers to creations of the mind, including inventions, literary and artistic works, symbols, names, images, and designs used in commerce. It grants creators exclusive legal rights to use and exploit

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Update on the Tax Dispute Resolution Process – 26 June 2018

This online seminar is presented by Prof. Dr. Daniel N. Erasmus and Schalk Pieterse, both experienced practitioners in this field. The 2 have worked together on numerous cases where Erasmus has been  instructed by Pieterse to argue the tax disputeTax Disputes arise when there is a disagreement between taxpayers and tax authorities regarding the interpretation

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South Africa: Controlled Foreign Companies (CFC’s)

By ENS Section 9D of the Income TaxIncome Tax is a direct levy imposed by governments on the income generated by individuals, corporations, and other entities within a specific jurisdiction. It serves as a major source of revenue for governments and funds various public expenditures, such as infrastructure projects, healthcare, education, national security, and welfare

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The OECD released two reports containing Guidance for Tax Administrations on the Application of the Approach to Hard-to-Value Intangibles, under BEPS Action 8; and Revised Guidance on the Application of the Transactional Profit Split Method, under BEPS Action 10

The 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

The OECD released two reports containing Guidance for Tax Administrations on the Application of the Approach to Hard-to-Value Intangibles, under BEPS Action 8; and Revised Guidance on the Application of the Transactional Profit Split Method, under BEPS Action 10 Read More »