South Africa: light at the end of the tunnel? The ConsCourt judgment against the Public Protector
Watch the judgment being delivered here: https://www.enca.com/news/livestream-concourt-delivers-judgment-mkhwebane-vs-reserve-bank
Category: FP News
The International Taxation of Autonomous Artificial Intelligence (AAI): Questions from Leopoldo Parada
Lucas de Lima Carvalho (Brazilian Institute for Tax LawTax laws form the backbone of any nation’s revenue system, setting the rules that govern how individuals and corporations contribute financially to support government functions. These laws define the types of taxes, the applicable rates, and the regulations regarding payment and compliance. They also outline the rights and obligations of taxpayers, ensuring a balanced and fair approach to funding public... (IBDT))/July 16, 2019 /Leave a comment This is the second article of a short series that explores
The Importance of the Marcopolo Cases for Understanding the Application of the Brazilian Transfer Pricing Rules
The Importance of the Marcopolo Cases for Understanding the Application of the Brazilian Transfer PricingTransfer pricing is a fundamental concept in international taxation that defines the pricing methods and rules applied to transactions between related entities within a multinational enterprise (MNE). In the context of tax regulations, it governs how prices for goods, services, or intangibles (such as intellectual property) are set when these items are exchanged between different branches, subsidiaries, or affiliates of... Rules Francisco Lisboa Moreira (Bocater Advogados) and Ana Paula Saunders (Vale S.A.)/July 10, 2019/Leave
A tale of three DTA’s: South African Tax Court confirms that no dividends tax is payable on distributions to Dutch resident shareholders
By FASKEN, The Netherlands In terms of section 64E(1)(a) of the Income TaxIncome Tax is a direct levy imposed by governments on the income generated
The OECD/Inclusive Framework’s Program of Work on Revised Nexus and Profit Allocation Rules (Pillar One): Where Will It Lead?
Jefferson VanderWolk, Robert O’Hare (Squire Patton Boggs)/June 25, 2019 /Leave a comment On June 9, 2019 the G20 finance ministers endorsed the program of work that was
S.Africa: South African Tax Court confirms application of the most favoured nation clause in the South Africa / Netherlands treaty
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 that dividend distributions from Dutch
GHANA: TP Country Summary
An excellent Ghana TP Country: For further information please send a request to Daniel@TaxRiskManagement.com
Canada: Two fairly recent transfer pricing cases
Cameco Corporation v. The Queen The Tax Court of Canada ruled on Cameco Corporation v. The Queen on 26th September 2018. The court ruled against
S.Africa: Grounds of assessment held to be unreasonable
… the grounds of assessment were unreasonable in two respects, namely the incorrect utilisation of the Net Asset Value (NAV) methodology and the Commissioner’s valuation