Zambia

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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S.Africa: The High Court considers the power of SARS to issue reduced assessments

In Rampersadh and Another v Commissioner of 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

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S.Africa: Far-reaching proposed changes to the taxation of foreign trusts

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

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US: Update on current TP cases in the US

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

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Place of Effective Management: Indian Perspective

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

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Zambia seeks USD22-million in tax on internet calls

Zambia seeks USD22-million in tax on internet calls Zambia expects to raise USD22-million annually in new tax on internet phone calls. The cabinet approved a 30 ngwee (0.3 kwacha; USD0.03) daily tariff charged on online phone calls. Transport and Communications Minister Brian Mushimba said that the government considered concerns raised by telecom operators. He added

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S.Africa: SARS interpretation note 4 (issue 5): resident: definition in relation to a natural person – physical presence test

SARS publications  interpretation note 4 (issue 5): resident: definition in relation to a natural person – physical presence test section 1(1) 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

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TP cases related to TP online course

Australia 2015 Article 9 Chevron Australia Holdings (Pty) Ltd v CoT [2015] FCA 1092 Australia Appeal 2017 Chevron Australia v Comm of Tax [2017 FCAFC 62] Australia Roche Products Pty Ltd (NT 2005_7 & 56-65) Australia-SNF-Australia-Pty-Ltd-v-Commissioner-of-Taxation-2010-FCA-635-25-June-2010 Canada GE Capital [2010 FCA 344] CanLII – 2010 FCA 344 (CanLII) Canada GE Capital [2010 FCA 344] summary

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