West Africa

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 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 […]

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

On 25 July 2018, 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 (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) 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

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

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 regulationsTax 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 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

OECDThe Organisation for Economic Co-operation and DevelopmentThe 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 (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) is an international organisation comprising 38 member countries, established to foster economic growth, trade, and development on a global scale. Founded in 1961, 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 is to promote policies that improve... More provides a forum for governments to collaborate, share policy experiences, and develop solutions to common economic challenges. The OECD’s core mission is

In Rampersadh and Another v Commissioner of 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 fiscal policy by collecting revenue, administering customs, and ensuring compliance with 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. Established

By ENSafrica The South African Draft Taxation Laws Amendment Bill, 2018 (the “Draft Bill”), which was published by the Minister of Finance on 16 July 2018, introduces many of the tax proposals announced in the 2018 Budget Review earlier this year. Consistent with the general trend of combatting perceived areas of 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, among the

Litigation Court Roundup: Updates in Facebook, Eaton and Coca-Cola Tax Cases The IRS, in Facebook Inc.’s latest challenge in the U.S. Tax Court, rejected the social network’s claim that it properly valued intangibles, including Instagram technology, that the company transferred to its Irish unit in 2013. The Internal Revenue ServiceTax authorities are fundamental institutions within

Mukesh Butani (BMR Legal) and Ashrita Prasad Kotha (Jindal Global Law School)/August 22, 2018 India introduced the place of effective management (POEM) in its domestic law in Finance Bill of 2015 but due to lack of preparedness it was deferred to April 1, 2017 and made applicable from assessment year 2017-2018. The statement of intent revealed that the purpose