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

640 articles

S.Africa: Landmark judgment in Supreme Court of Appeal upholds deferred delivery share scheme

Landmark judgment in Supreme Court of Appeal upholds deferred delivery share scheme Commissioner SARS v Bosch (394/2013) [2014] ZASCA 171…

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S.Africa: New money Bills – October 2014

Here are the copies of the following Bills introduced in Parliament:- 1. Taxation Laws Amendment Bill 2. Rates and Monetary

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S.Africa: Preservation Orders & Tax

Preservation orders DLA Cliffe Dekker Hofmeyr Heinrich Louw South Africa October 17 2014 Here is the actual judgment: SA Tax Cases

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Zimbabwe: Tax system in a nutshell

Zimbabwe tax system in a nutshell Celia Becker ENSafrica, South Africa Celia Becker is Tax Advisor at ENSafrica in Johannesburg. I.…

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Botswana: Tax system in a nutshell

Botswana tax system in a nutshell Celia Becker ENSafrica, South Africa Celia Becker is an Africa regulatory and business intelligence

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S.Africa: Proposed Changes to Secondary TP Adjustment

Proposed Changes to Secondary Transfer Pricing Adjustment South Africa’s National Treasury and the South African Revenue Service (SARS)…

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S.Africa: Shuttleworth wins SCA case against the SARB to refund $22m paid in a…

http://www.justice.gov.za/sca/judgments/sca_2014/sca2014-157.pdf For a summary of the case:…

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Nigeria: Interest On Intercompany Loan Incurred By An Oil Company Is Tax Deductible Subject To…

Nigeria: Interest On Intercompany Loan Incurred By An Oil Company Is Tax Deductible Subject To Transfer Pricing Rules Last Updated:

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S.Africa: Electronic assessments by SARS through eFiling? Is this proper notification?

In a DeRebus October 2014 article the author Alan Lewis concludes: “In my opinion, neither the provisions of the Tax

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S.Africa: SARS have introduced a new modernised tax return for Trusts

S.Africa: SARS have introduced a new modernised tax return SARS will soon be introducing a new modernised Income Tax Return

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S.Africa: Missed the NEW TAA Dispute Resolution seminar – here is the recording

Missed the NEW TAA Dispute Resolution seminar Here is the recorded version: I delivered a 4 hour detailed seminar on

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BRICS: Potential influence in Africa of China beneficial ownership case where preferential…

BRICS: Potential influence in Africa of China beneficial ownership case where preferential dividend rate denied – WITH further explanations…

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S.Africa: Customs & Excise reclassification – importance of evidence

http://www.saflii.org/za/cases/ZASCA/2013/145.html Bowman Gilfillan Virusha Subban September 19 2014 The Supreme Court of Appeal recently…

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Africa: Status of Transfer Pricing in Africa (Part 1)

Status of transfer pricing in Africa (Part I) ENSafrica Celia Becker Status of transfer pricing in Africa (Part I) Tanzania

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S.Africa: Disposal of foreign equity shares – proceed with caution

Disposal of foreign equity shares – proceed with caution ENSafrica Peter Dachs and Bernard Du Plessis South Africa September 16 2014 In

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Mauritius: Mauritius further enhances its position as an offshore jurisdiction of choice with 4…

Article by Malcolm Moller and Sharmilla Bhima Appleby The Government of the Republic of Mauritius (Government of Mauritius) has ratified…

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Transfer Pricing: 25{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e} rule of…

Transfer Pricing: 25{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e} rule of thumb not applicable to determining royalty…

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OECD: Seven BEPS Actions issued September 16, 2014

COMMENT BY DR. D.N. ERASMUS – This is a summary of an article first published in a Bloomberg BNA Transfer

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S.Africa: Proposed changes to secondary transfer pricing adjustment

DLA Cliffe Dekker Hofmeyr Heinrich Louw South Africa September 12 2014 National Treasury and the South African Revenue Service (SARS)

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OECD: First recommendations for combating international tax avoidance by multinational…

http://www.oecd.org/tax/oecd-to-release-first-recommendations-for-combating-international-tax-avoidance-by-multinational-enterprises-on-tues…

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S.AFRICA: Expenditure relating to deferred accruals

Expenditure relating to deferred accruals DLA Cliffe Dekker Hofmeyr Heinrich Louw South Africa September 5 2014 Background The taxpayer…

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S.AFRICA: Section 14 of the Prescription Act, No 56 of 1972 – a life line

DLA Cliffe Dekker Hofmeyr Jackwell Feris South Africa September 10 2014 Section 14 of the Prescription Act, No 56 of

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S.AFRICA: Recent tax case – Fringe benefits planning ‘faux pas’ on a company car & other…

S.AFRICA: Recent tax case – Fringe benefits planning ‘faux pas’ on a company car & other benefits – or not?

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S.AFRICA: Documentation in tax disputes highlighted in the New dispute resolution rules

Article by Stephen Levetan and Taryn Solomon ENSafrica The new rules promulgated under section 103 of the Tax Administration Act No. 28 of

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