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

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TP Lecture week 15 – Intangibles Part I

Pre-recorded lecture – Intangibles Part I https://www.dropbox.com/sh/v7urmo9vu9bx4i1/AABqDiu1S48Zog1ajCtmv5Tda?dl=0 Follow curriculum –…

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TP Lecture week 14 – Intra-group services Part II

Follow curriculum – Reading: OECD TPG Transfer Pricing Guidelines for Multinational Enterprises and Tax Administration July 2017 Chapter…

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TP Lecture week 13 – Intra-group services Part I

Follow curriculum – Reading: OECD TPG Transfer Pricing Guidelines for Multinational Enterprises and Tax Administration July 2017 Chapter…

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TP Lecture week 12 – Comparability analysis Part III

Follow curriculum – Reading: OECD TPG Transfer Pricing Guidelines for Multinational Enterprises and Tax Administration July 2017 Chapter…

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TP Lecture week 11 – Comparability analysis Part II

Follow curriculum – Reading: OECD TPG Transfer Pricing Guidelines for Multinational Enterprises and Tax Administration July 2017 Chapter…

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TP Lecture week 10 – Comparability analysis Part I

Follow curriculum – Reading: OECD TPG Transfer Pricing Guidelines for Multinational Enterprises and Tax Administration July 2017 Chapter…

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TP Lecture week 9 – TP methods

Follow curriculum – Reading: OECD TPG Transfer Pricing Guidelines for Multinational Enterprises and Tax Administration July 2017 Chapter…

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TP Lecture week 8 – TP methods

Follow curriculum – Reading: OECD TPG Transfer Pricing Guidelines for Multinational Enterprises and Tax Administration July 2017 Chapter…

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TP Lecture week 7 – TP methods

Follow curriculum – Reading: OECD TPG Transfer Pricing Guidelines for Multinational Enterprises and Tax Administration July 2017 Chapter…

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TP Lecture week 6 – Functional analysis

Follow curriculum – Reading: OECD TPG Transfer Pricing Guidelines for Multinational Enterprises and Tax Administration July 2017 Chapter 1:…

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TP Lecture week 5 – ALP and introduction to comparability

Follow curriculum – Reading: OECD TPG Transfer Pricing Guidelines for Multinational Enterprises and Tax Administration July 2017 Chapter 1:…

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TP Lecture week 4 – Legal Framework

Listen to the following intro to TP and TP cases (where short summary of lecture is part of the week’stutorial):

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S.Africa: Davis Tax Committee final reports April 2018

It’s complete: The Davis Tax Committee releases its final reports Cliffe Dekker Hofmeyr South Africa April 13 2018 On 12 April

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S.Africa Tax Court and Appeals: Raising jurisdictional issues

Raising jurisdictional issues Cliffe Dekker Hofmeyr South Africa April 13 2018 Where a taxpayer is dissatisfied with the decision taken by

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Tax Controversy Workshop (International Tax & TP) in Amsterdam 21 June 2018

Details of the one-day conference: Global Tax Controversy – Workshop for Corporates

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US TP the pre-trial memorandum in the Coca-cola intangibles case and various articles

Download a copy here: US TP 2018 Coca Cola case petitioner’s pre-trial memorandum To understand the applicable TP principles applicable

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SARS defective Notice of Appeal DRAFT application – why SARS abandoned the appeal of the Letter…

The defective SARS Notice of Intention to Appeal: REDACTED Appeal intention and TAA provisions_Redacted DRAFT application to the High Court:

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SARS issues new guide to understatement penalties – a march toward further certainty?

SARS issues new guide to understatement penalties – a march toward further certainty? Cliffe Dekker Hofmeyr April 6 2018 The

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What is Bitcoin and its taxation consequences

Abdulkadir Kahraman KPMG Turkey Abdulkadir Kahraman is Partner and Head of Tax at KPMG Turkey Reality of the Digital Economy

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Future expenses deductible now – a judgment about Section 24c of the Income Tax Act

Future expenses deductible now – a judgment about Section 24c of the Income Tax Act Cliffe Dekker Hofmeyr South Africa March

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Zimmer Ltd. vs. Germany (2018): Implications for International Taxation and Transfer Pricing

Explore our detailed analysis of the Zimmer Ltd. vs. Germany (2018) case. Learn how this ECJ judgment impacts the definition of Permanent…

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GlaxoSmithKline v. CIR (Philippines)

In GlaxoSmithKline (GSK) Philippines, Inc. v. Commissioner of Internal Revenue (CIR), the Supreme Court of the Philippines upheld a tax…

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2018 South African Budget Speech

South Africa Report from our correspondent Lutando Mvovo, South Africa Budget for 2018-19 – direct taxation The Budget for 2018-19

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US: GILTI onerous for non-C corporation CFC shareholders

GILTI rules particularly onerous for non-C corporation CFC shareholders McDermott Will & Emery USA February 9 2018 Summary The recently…

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