Latest tax posts

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

Corporate tax planning developments in South Africa

ENSafrica A company is defined in the Income Tax Act, 58 of 1962 (the Income Tax Act) as including any

OECD and EU updates on TP related issues

OECD consults on “Pillar Two” global minimum tax proposal November 8, 2019 The OECD Secretariat today released a consultation document

Revenue Statistics in Africa 2019

The 2019 edition of the tax policy publication Revenue Statistics in Africa…

Monitoring and enforcing: Determining if MNEs pay their “fair share” of New Zealand tax.

The Inland Revenue document Multinational Enterprises Compliance Focus (2019) focuses on the base erosion and profit shifting (BEPS)…

TP Lecture week 2.2 – Legal Framework

Follow the curriculum – Reading: For a useful comparative tool on TP country-by-country, look at: https://www.lexology.com/navigator# and…

TP Lecture week 2.1 – Legal Framework

Live tutorial materials: Follow the curriculum – Reading: For a useful comparative tool on TP country-by-country, look at:…

TP Lecture week 1 – TP Legal Framework

General background summary reading for a FULL overview of TP, in this order, which should be your ongoing reading during

OECD secretariat invites public input on the Global Anti-Base Erosion (GloBE) Proposal under…

In May 2019, the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework) agreed a Programme of Work for Addressing the Tax Challenges of…

BEPS requirements on CbC Reporting – Background reading

Please see the following document as background reading:…

Recent TP Cases

TP Judgments in Africa The first Ghana TP case – TP Ghana JUDGMENT IN TAX APPEAL CASE BETWEEN BIERSDORF GH LTD AND THE

S.Africa: Recent cases relevant to tax issues – summarised

Public Protector v South African Reserve Bank (CCT107/18) [2019] ZACC 29; 2019 (9) BCLR 1113 (CC) (22 July 2019) The issues

S.Arica updates: Foreign Employment Income Exemption & SARS issues updated list of…

South Africa Report from our correspondent Lutando Mvovo, South Africa Foreign Employment Income Exemption; Frequently Asked Questions…

TP Minds conference in Johannesburg: TP case update by Prof. Dr. Daniel N. Erasmus

Below is a link to the short presentation on the latest Africa TP cases and the experience of Dr. Erasmus

TP judgments in Africa – as at Nov 2019

Here is a list of the current cases: The first Ghana TP case – TP Ghana JUDGMENT IN TAX APPEAL CASE

Africa Brief 28 Oct 2019

Africa Doing Business 2020: Two sub-Saharan African countries among most improved in Ease of Doing Business Economies in sub-Saharan Africa