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Commentary, playbooks and updates from the Academy and its faculty.

640 articles

ZIMBABWE: Income tax (transfer pricing documentation) regulations 2019 issued

The Minister of Finance and Economic Development issued the Income Tax (Transfer Pricing Documentation) Regulations 2019 by Statutory…

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Mauritius 2019 Budget Speech

The Prime Minister of Mauritius presented the Mauritian Budget Speech for the 2019/20 year yesterday. The important tax proposals, insofar…

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Tax risk management free pdf book

by Dr Daniel N Erasmus PhD EA USTCP Int’l Tax Attorney Tax Risk Management is more relevant than

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TP articles in DTAs being used as “tax charging sections”

Here are the recent cases where the courts have considered whether or not Article 9 Associated Enterprise or it’s equivalent

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TP: A short course in drafting TP related Agreements

Not only is theory important on TP. But how does this translate into practice. Here is a useful short course

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UN TPGs

Here are the latest UN TPGs:…

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Supporting documents to the TP Introduction and Update Seminar

The Continuing Education Questions are at the bottom of this page. Seminar recordings: Lecture 1 –…

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KENYA: High Court ruling on Mauritius treaty

By ENS Africa update – KENYA: High Court ruling on Mauritius treaty On 15 March 2019, The High Court of

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Anwar & Co. v. CIT: Understanding Permanent Establishment in International Taxation

The case of Anwar & Co. v. CIT is a landmark ruling by the Supreme Court of India that delves deep into Permanent Establishment (PE) and…

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Zimbabwe: Income tax (transfer pricing documentation) regulations 2019 – issued

Zimbabwe Report from our correspondent Gershem T. Pasi, Revenue and Business Consultant, Zimbabwe Income tax (transfer pricing…

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The IFA MAURITIUS 13th ASIA/AFRICA CONFERENCE 2019

POEM Panel notes: http://iitfconnect.com/wp-content/uploads/2019/05/Poem-Panel-IFA-Mauritius-2019.pptx POEM notes:…

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India: Recent Transfer Pricing cases – over case 900 summaries

Application of Transfer Pricing provisions not against “non-discrimination” clause of DTAA; DCF valuation subsumes goodwill: In the…

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S.Africa: The “Expat Tax” and Financial Emigration

29 April 2019 In the wake of another budget deficit, SARS looks toward South Africans living abroad to help close

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Africa is being left out of the digital tax loop – by Daily Maverick

Google parent company Alphabet reported recently its full-year results for 2018, announcing income of $30-billion off a revenue of…

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Ghana: Pay some tax before filing tax appeal

GHANA: High Court rules that payment of minimum disputed amount is a prerequisite for filing an appeal The Commercial Division

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S.Africa: Country by Country reporting

Country-by-Country Reporting and Transfer Pricing SARS issued a public notice on 20 October 2017 which stipulates the requirements and…

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TP Zambia: Nestle Zambia Trading Ltd v ZRA

Here is a FULL copy of the case. Although there is a useful summary below, read the full case for

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A creature of statute: A decision about the Tax Court’s power to increase understatement…

In the recent judgment of Purlish Holdings (Proprietary) Limited v The Commissioner for the South African Revenue Service (76/18) [2019]

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S.Africa: Your taxpayer rights – Tax Dispute Resolution principles

https://www.linkedin.com/feed/update/urn:li:activity:6511218979674169344/

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S.Africa: 20 February 2019 Budget – tax proposals

Budget speech tax proposals:…

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S.Africa: A diver’s quandary: The role of domestic law in interpreting double taxation…

Cliffe Dekker Hofmeyr In the international tax law arena, agreements for the avoidance of double taxation (DTAs) are, very simply,

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SSRN Research Papers download – Tax Planning and other Papers to download

SSRN Research Papers Congratulations Dr Daniel N Erasmus You are currently in the top…

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TRANSFER PRICING BUSINESS MODELS

By Angela Sadang | January 27, 2017 | Download PDF Once the initial transfer pricing interviews (i.e. functional analysis interviews) have…

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S.Africa: Win for the employer: Judgment on the Employment Tax Incentive Act

By CDH Cliffe Dekker Hofmeyr – Louis Botha and Louise Kotze In the recent case of ABC (Pty) Ltd v The Commissioner for the

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