Latest tax posts

Belgium applies “formal interpretation” when doing foreign management and control test

Belgium applies “formal interpretation” when doing foreign management and control test On 23 November 2017, the Brussels Court of Appeal

Nigeria: Court rules imported services VATable in Nigeria

NIGERIA: Court rules that imported services are taxable in Nigeria The Court of Appeal in the Lagos Judicial Division, in

NEW certificate in tax dispute resolution

https://mailchi.mp/904928007711/certificate-in-tax-dispute-resolution-2020 Convenor: Dr Daniel N Erasmus, brings years of practical tax…

TP Minds conference in Johannesburg: 29/30 October

Conference: 29 & 30 October 2019Venue: Radisson Blu Hotel SandtonJohannesburg VIEW LATEST AGENDA The international tax landscape is…

IBFD country updates

Country Surveys – these require an IBFD subscription Botswana by Jude Amos(Reviewed up to 14 June 2019)Corporate TaxationGeneral…

South Africa: Wingate-Pearse v Commissioner for the South African Revenue Service and others…

Wingate-Pearse v Commissioner for the South African Revenue Service and others [2019] JOL 45120 (GJ) Name of Court: High Court

AI and Taxation: Risk Management in Fully Automated Taxation Procedures

12 Pages Posted: 19 Dec 2018 Nadja Braun Binder University of Zurich – Faculty of Law Date Written: October 1, 2018

Tax Risk Survey: Please complete this short survey indicating tax risks…it will take a few…

Here is the link to the survey: https://www.surveymonkey.com/r/V35HCQS Here are the results: There is more attention being paid to managing

South Africa: DRAFT Tax Amendments

South AfricaDraft Rates and Monetary Amounts and Amendment of Revenue Laws Bill 2019 issued for public comment; South AfricaDraft Tax

Mauritius: MAURITIUS LEAKS Treasure Island: Leak Reveals How Mauritius Siphons Tax From Poor…

Based on 200,000 files, Mauritius Leaks exposes a sophisticated system that diverts tax revenue from poor nations back to the

Something other than tax: Constructing an Alcubierre Warp Drive The possibility of faster than…

If you are a space travel fan: WARP travel faster than the speed of light is possible. It would require

South Africa: light at the end of the tunnel? The ConsCourt judgment against the Public…

Watch the judgment being delivered here: https://www.enca.com/news/livestream-concourt-delivers-judgment-mkhwebane-vs-reserve-bank

South Africa: Recent tax and administrative law

The International Taxation of Autonomous Artificial Intelligence (AAI): Questions from Leopoldo…

Lucas de Lima Carvalho (Brazilian Institute for Tax Law (IBDT))/July 16, 2019 /Leave a comment This is the second article of

The Importance of the Marcopolo Cases for Understanding the Application of the Brazilian…

The Importance of the Marcopolo Cases for Understanding the Application of the Brazilian Transfer Pricing Rules Francisco Lisboa Moreira…

A tale of three DTA’s: South African Tax Court confirms that no dividends tax is payable on…

By FASKEN, The Netherlands In terms of section 64E(1)(a) of the Income Tax Act 58 of 1962 (“the ITA”) dividends

The OECD/Inclusive Framework’s Program of Work on Revised Nexus and Profit Allocation Rules…

Jefferson VanderWolk, Robert O’Hare (Squire Patton Boggs)/June 25, 2019 /Leave a comment On June 9, 2019 the G20 finance ministers endorsed…

S.Africa: South African Tax Court confirms application of the most favoured nation clause in…

By DLA Piper In our Global Tax Alerts in February 2018 and January 2019 we discussed the Dutch Court of Appeal’s decision which held

GHANA: TP Country Summary

An excellent Ghana TP Country: For further information please send a request to Daniel@TaxRiskManagement.com

Canada: Two fairly recent transfer pricing cases

Cameco Corporation v. The Queen The Tax Court of Canada ruled on Cameco Corporation v. The Queen on 26th September

S.Africa: Grounds of assessment held to be unreasonable

… the grounds of assessment were unreasonable in two respects, namely the incorrect utilisation of the Net Asset Value (NAV)

KENYA: The Kenya/Mauritius DTA declared invalid – why?

VI. Conclusion It is astounding to this writer that in the aftermath of the decision in TJN-A v KRA, the

Malawi: Tax issues – TREASURY FAULTED ON INVESTOR TAX BURDEN

STEVE CHILUNDU Staff Reporter Economists and tax experts have faulted Treasury for introducing tax policies that are not favourable in

Digest of Important Judgments on Transfer Pricing and International tax – 2018

http://www.fitindia.org/downloads/digest_of_1350_it_and_tp_cases_2018.pdf The Digest contains 1350 important judgments which were…