South Africa Archives - Page 2 of 25

Landmark Transfer Pricing Case from South Africa

International, International Tax, South Africa, Tax Dispute Resolution, Transfer Pricing / Dr Daniel N Erasmus

TRM Tax Attorneys secures landmark victory in South Africa’s first 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 case, demonstrating expertise in resolving complex 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 pricing adjustments. Tax disputes can lead to lengthy legal proceedings... More. Learn how Prof Dr Daniel N Erasmus and his team can assist you.

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South Africa’s First Transfer Pricing Case

International, International Tax, South Africa, Tax Dispute Resolution, Transfer Pricing / Dr Daniel N Erasmus

Explore how TRM’s expertise in 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 challenges in South Africa helped ABD Limited win against 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, offering insights for multinationals.

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South Africa’s first Transfer Pricing case, and it’s a win for the taxpayer!

International, South Africa, Tax Dispute Resolution, Transfer Pricing / Dr Daniel N Erasmus

Can we hear a “woohoo”!? Yes, you read right, South Africa has finally had its first TP case and whaddaya know, the taxpayer won!

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ABD Limited vs. SARS Transfer Pricing Dispute Judgment

Africa, International, South Africa, Tax Dispute Resolution, Transfer Pricing / Dr Daniel N Erasmus

Explore the critical analysis of the transfer pricing dispute judgment between ABD Limited and 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, focusing on IP royalties and tax implications.

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DID YOU MISS THE MASTERING TAX DISPUTE RESOLUTION IN SOUTH AFRICA WORKSHOP?

Dispute Resolution, South Africa, Tax Dispute Resolution / Dr Daniel N Erasmus

This workshop was designed to give aspiring and practising tax professionals an overview of what is needed to navigate the complex terrain of tax audits, assessments, objections, appeals, tax boardTax 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 hearings, and emerging developments in tax legislationTax 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.

DID YOU MISS THE MASTERING TAX DISPUTE RESOLUTION IN SOUTH AFRICA WORKSHOP? Read More »

SOUTH AFRICA: The Impact of Global Minimum Corporate Tax on Multinationals

Africa, International, International Tax, South Africa / Dr Daniel N Erasmus

Explore the implications of the new global minimum corporate taxCorporate Tax refers to the tax imposed by governments on the income or capital of corporations. Corporations, considered separate legal entities, are taxed on their profits, meaning the income generated from their operational activities, investments, and other financial undertakings. This tax is generally a key revenue source for governments, helping to fund public services, infrastructure, and other essential functions. The... More for multinational corporations, including both challenges and opportunities.

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SOUTH AFRICA: Kusasa Refining (Pty) Ltd v Commissioner for South African Revenue Services

Africa, South Africa / Dr Daniel N Erasmus

The case involves the failure of 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 to finalize the value added tax (VAT) audit of Kusasa Refining for the period from January 2019 to February 2021, despite the company providing all the requested information and documents.

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GTC Conference 2023

Africa, South Africa, Transfer Pricing / Dr Daniel N Erasmus

I/I/T/F Head of Academic Development, Prof Dr Daniel N. Erasmus was in attendance at the event and delivered a key-note presentation on:

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 – THE NOOSE TIGHTENS FURTHER

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Emerging Trends in Transfer Pricing

South Africa, Transfer Pricing / Dr Daniel N Erasmus

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 (TP) disputes have always posed challenges to 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) and tax authorities. The interpretation and implementation of arm’s length principles, the backbone of TP regulations, have led to an increasing number of TP disputes across the globe. This article considers emerging trends, emphasising the critical role of TP expert witnesses in any TP dispute.

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Unlocking the Complexities of Tax Dispute Resolution in South Africa:

Africa, Dispute Resolution, South Africa / Dr Daniel N Erasmus

In the ever-evolving landscape of taxation, the ability to navigate tax disputes effectively is more crucial than ever. I am thrilled to introduce our newly launched fully online course, “MASTERING TAX DISPUTETax 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 pricing adjustments. Tax disputes can lead to lengthy legal proceedings... More RESOLUTION IN SOUTH AFRICA.”

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