Latest tax posts

AN ANALYSIS OF CHALLENGING THE COMMISSIONER’S DISCRETIONARY POWERS INVOKED to Audit in terms OF…

https://www.academia.edu/s/fc609c8e64?source=link The PH.D. thesis is equally applicable to the new Tax Administration Act, 2011.

Postgraduate Diploma in International Taxation Course Start Date: 31st March 2020

Brand new course to help grow your international taxation career in 2020… Postgraduate Diploma in International TaxationCourse Start Date:…

The Inclusive Framework is considering radical proposals, but in the real world… – Ben Dickinson

In her recent blog, Allison Christians usefully alerts us to some of the challenges and opportunities of the new rules on international

OECD Invites Taxpayer Input On Tenth Batches Of Dispute Resolution Peer Reviews

The OECD is now gathering input for the Stage 1 peer reviews of Andorra, Aruba, Bahrain, Barbados, Gibraltar, Greenland, Kazakhstan,

USA – The Attorney-Client Privilege Does Not Protect Client Identities – Richard A. Nessler…

In Taylor Lohmeyer Law Firm PLLC v. United States,1 the Taylor Lohmeyer Law Firm (the “Firm”) unsuccessfully challenged a John Doe summons

Assessment of Principles and Practices ofGood Governance in Tax Administration

Click to download

The DAC6 Intermediary: multiplying compliance-costs and creating loopholes – Martijn Weijers…

In June 2017, the European Commission published its proposal on transparency rules for tax planning by intermediaries and certain taxpayers

OECD – Release of Revenue Statistics in Africa 2019

The average tax-to-GDP ratio for the 26 countries participating in the new edition of Revenue Statistics in Africa was unchanged at…

Irish Corporation Tax Revenue Touches Euros 10.4 Billion

A new paper published by Ireland’s Department of Finance reveals that corporation tax revenues have experienced a significant increase in

TAX PLANNING AS PART OF A TAX RISK MANAGEMENT PROCESS Makes SSRN Top 10

Dear Dr Daniel N. Erasmus: Your paper, “TAX PLANNING AS PART OF A TAX RISK MANAGEMENT PROCESS”, was recently listed

US Tax Court resolves Eaton’s transfer pricing dispute – By Elisa Kaminsky, BaseFirma, Miami

The US Tax Court issued a written opinion on October 28 regarding Eaton’s transfer pricing court case. The resolution of

Poland’s new cooperative compliance program for large taxpayers – By Dr. Monika Laskowska,…

On 6 November, Poland’s President signed a law implementing a new cooperative compliance program in Poland for large corporate taxpayers

The United Nations’ effort to shape global transfer pricing policy – By George L. Salis,…

The 19th Session of the United Nations Committee of Experts on International Cooperation in Tax Matters was held October 15-18

OECD releases 2500+ pages of public comments to its pillar one “unified approach” for taxing…

The OECD on November 15 published more than 300 comment letters that respond to its request for feedback on the

China simplifies procedure for claiming tax treaty benefits – By Agnes Lo, Lingnan University,…

China’s State Taxation Administration on 14 October published “Administrative Measures for Non-resident Taxpayers Claiming Tax Treaty…

OECD seeks feedback on the effectiveness of 13 countries’ cross-border tax dispute resolution…

The OECD today requested input from taxpayers to assist in an assessment of the timeliness and efficiency of the cross-border

Colombia issues new guidance on the taxation of permanent establishments and branches – By…

On October 29, the Colombian government published Decree 1973, providing detailed rules on the attribution of income to a permanent

The GloBE puzzle: a debate way beyond use of financial accounts – By Dr. Leopoldo Parada,…

A few days before closing the public consultation on the OECD Secretariat’s pillar 1 unified approach, the OECD released a

WTO: Pushing exports: India must rethink trade policy

By: Mukesh Butani | Published: November 18, 2019 4:34:32 AM While the trade policy mandarins of the GoI will look for solutions, the

Tax Treaty Overrides: A Qualified Defense of U.S. Practice – Reuven S. Avi-Yonah

The ability of some countries to unilaterally change, or “override,” their tax treaties through domestic legislation has frequently been…

An analysis of the South African general anti-avoidance rules: Exploring Australian judicial…

The decisions of recent Australian case law relating to the general anti-avoidance regime was cause for concern among the Australian

GAAR AS TAX TREATY OVERRIDE – SLOVAK PERSPECTIVE

Download GAAR AS TAX TREATY OVERRIDE – SLOVAK PERSPECTIVE

South African Reserve Bank: Excon Circular 18 of 2019 – Loop Rules Individuals

Historical Evolution on Transfer Pricing and Value Creation