West Africa

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 »

South Africa – Reducing the cost of transfer pricing compliance for MNEs

Many countries have become more focused on combating tax avoidance. As such, 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

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The OECD and the African Tax Administration Forum (ATAF) signed a renewal of their Memorandum of Understanding (MoU) until June 2023

Today, 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

The OECD and the African Tax Administration Forum (ATAF) signed a renewal of their Memorandum of Understanding (MoU) until June 2023 Read More »

Supreme Court of Appeal upholds High Court ruling setting aside unlawful rates regime

Recently, the Supreme Court of Appeal (“SCA”) upheld a ruling handed down by the High Court in Pretoria 2 years ago, setting aside an exorbitant rates regime implemented by the City of Tshwane Metropolitan Municipality. The unlawful property rates regime arose following the amalgamation of the former Kungwini Municipality into the City of Tshwane. When

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SARS’ new DRAFT Mutual Agreement Procedure

SARS MAP Guide DRAFT 2018 Draft Guide on MAPs CONTENTS Preface…………………………………………………………………………………………………………………ii Glossary ………………………………………………………………………………………………………………1 1. Background ……………………………………………………………………………………………….1 1.1 What is a mutual agreement procedure?………………………………………………………………………..2 1.2 Legal basis for mutual agreement procedure ………………………………………………………………….5 1.3 Multilateral Instrument………………………………………………………………………………………………….6 1.4 The role of a competent authority ………………………………………………………………………………….7 1.5 South Africa mutual agreement procedure profile and website………………………………………….7 2. In what instances

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