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
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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
Read more →An excellent Ghana TP Country: For further information please send a request to Daniel@TaxRiskManagement.com
Read more →Cameco Corporation v. The Queen The Tax Court of Canada ruled on Cameco Corporation v. The Queen on 26th September
Read more →… the grounds of assessment were unreasonable in two respects, namely the incorrect utilisation of the Net Asset Value (NAV)
Read more →VI. Conclusion It is astounding to this writer that in the aftermath of the decision in TJN-A v KRA, the
Read more →STEVE CHILUNDU Staff Reporter Economists and tax experts have faulted Treasury for introducing tax policies that are not favourable in
Read more →http://www.fitindia.org/downloads/digest_of_1350_it_and_tp_cases_2018.pdf The Digest contains 1350 important judgments which were…
Read more →The Minister of Finance and Economic Development issued the Income Tax (Transfer Pricing Documentation) Regulations 2019 by Statutory…
Read more →The Prime Minister of Mauritius presented the Mauritian Budget Speech for the 2019/20 year yesterday. The important tax proposals, insofar…
Read more →by Dr Daniel N Erasmus PhD EA USTCP Int’l Tax Attorney Tax Risk Management is more relevant than
Read more →Here are the recent cases where the courts have considered whether or not Article 9 Associated Enterprise or it’s equivalent
Read more →Not only is theory important on TP. But how does this translate into practice. Here is a useful short course
Read more →The Continuing Education Questions are at the bottom of this page. Seminar recordings: Lecture 1 –…
Read more →By ENS Africa update – KENYA: High Court ruling on Mauritius treaty On 15 March 2019, The High Court of
Read more →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…
Read more →POEM Panel notes: http://iitfconnect.com/wp-content/uploads/2019/05/Poem-Panel-IFA-Mauritius-2019.pptx POEM notes:…
Read more →Application of Transfer Pricing provisions not against “non-discrimination” clause of DTAA; DCF valuation subsumes goodwill: In the…
Read more →29 April 2019 In the wake of another budget deficit, SARS looks toward South Africans living abroad to help close
Read more →Google parent company Alphabet reported recently its full-year results for 2018, announcing income of $30-billion off a revenue of…
Read more →GHANA: High Court rules that payment of minimum disputed amount is a prerequisite for filing an appeal The Commercial Division
Read more →Country-by-Country Reporting and Transfer Pricing SARS issued a public notice on 20 October 2017 which stipulates the requirements and…
Read more →Here is a FULL copy of the case. Although there is a useful summary below, read the full case for
Read more →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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