Zambia

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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Blockchain links to research and understanding more on potential international tax issues

More on blockchain and the cryptocurrency – Ethereum Well to quote Blockgeeks: Every single operation that takes part in Ethereum, be it a simple transaction, or a smart contract, or even an ICO takes some amount of gas. Gas is what is used to calculate the amount of fees that need to be paid to

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How blockchain will assist advisors to become more strategic in their advisory roles

Many have observed that technology will free up time for lawyers to engage in more strategic and higher value activities. To be better problem-solvers, more commercial and more creative. What do these concepts mean? What kinds of skills are involved?You often hear clients describe a good lawyer as someone who is commercial, practical, creative, strategic, etc. But

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Digital economy and taxation presentation at the IFA Tax Conference in Mauritius

AI Robotics the future taxes – A US perspective-2 Why 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

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South Africa – Cryptocurrency – I believe SARS is wrong in part of their analysis

My view – where cryptocurrency is held as a currency to buy goods or services, when its value is released on buying those goods or services as a currency, there should be no tax consequence.  Just like when you hold dollars, that are converted to Rands when you buy goods and services. You are not

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