FP News Archives - Page 21 of 39

A creature of statute: A decision about the Tax Court’s power to increase understatement penalties – Cliffe Dekker Hofmeyr

In the recent judgment of Purlish Holdings (Proprietary) Limited v The Commissioner for the South African Revenue ServiceThe South African Revenue ServiceThe South African Revenue Service (SARS) is the official tax authority responsible for the administration and enforcement of tax laws in South Africa. It plays a crucial role in managing the country’s fiscal policy by collecting revenue, administering customs, and ensuring compliance with tax legislation. Established under the South African Revenue Service Act, No. 34 of 1997, SARS functions independently... More (SARSThe South African Revenue Service (SARS) is the official tax authority responsible for the administration and enforcement of tax laws in South Africa. It plays a crucial role in managing the country’s fiscal policy by collecting revenue, administering customs, and ensuring compliance with tax legislation. Established under the South African Revenue Service Act, No. 34 of 1997, SARS functions independently... More) is the

ATL-Editor 22 March 2019

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

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

ATL-Editor 13 March 2019

S.Africa: 20 February 2019 Budget – tax proposals

Budget speech tax proposals: http://www.treasury.gov.za/documents/national{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20budget/2019/review/Annexure{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20C.pdf SARS’ own tax guide: http://www.treasury.gov.za/documents/national{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20budget/2019/sars/Budget{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}202019{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Tax{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Guide.pdf

ATL-Editor 21 February 2019

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

Cliffe Dekker Hofmeyr In the international tax lawTax laws form the backbone of any nation’s revenue system, setting the rules that govern how individuals and

ATL-Editor 19 February 2019

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 10{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e} of Authors on SSRN by all-time downloads. Check out your

ATL-Editor 19 February 2019

TRANSFER PRICING BUSINESS MODELS

By Angela Sadang | January 27, 2017 | Download PDF Once the initial transfer pricingTransfer pricing is a fundamental concept in international taxationFOR MORE INSIGHT ON INTERNATIONAL TAXATION, PLEASE READ THIS ARTICLE: Introduction to International Taxation: Key Concepts & Guidelines International Taxation encompasses the framework of laws, principles, and treaties that govern the tax obligations of individuals and entities engaged in economic activities that span multiple jurisdictions. This field addresses how income, profits, and gains are taxed when operations or investments extend... More that defines the pricing methods and

ATL-Editor 17 February 2019

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 South African Revenue ServiceThe South

ATL-Editor 16 February 2019

Global Tax Alert: Dutch Supreme Court confirms dividend withholding tax exemption under treaty between South Africa and the Netherlands

DLA PIPER In our Global Tax Alert on February 5, 2018, we discussed the decision of the Dutch Court of Appeal (‘s-Hertogenbosch) which held that dividend distributions

ATL-Editor 6 February 2019

S.Africa: When must a reportable arrangement be disclosed to SARS?

By Ben Strauss, Cliffe Dekker Hofmeyr Attorneys Under the Tax AdministrationTax authorities are fundamental institutions within government frameworks, overseeing tax assessmentA tax assessment is a formal determination made by a tax authority to calculate the amount of tax an individual or entity owes. It is a comprehensive evaluation based on financial records, declared income, expenses, deductions, and any applicable tax laws or regulations. Tax assessments may arise from routine self-assessments by taxpayers, or they may be conducted by revenue authorities... More, collection, and administration. Their

ATL-Editor 6 February 2019

UN tax committee to update to key transfer pricing manual for developing countries

By Julie Martin, Editor, MNEWhat are Multinational EnterprisesWhat are Multinational Enterprises (MNEs)? Multinational Enterprises, commonly referred to as MNEs, are corporations that operate in multiple countries through various subsidiaries, branches, or affiliates. These entities maintain a central management structure while leveraging diverse resources, labour markets, and customer bases across borders. The fundamental aspect that distinguishes MNEs from other corporate forms is their cross-border activity, which can include... More (MNEsWhat are Multinational Enterprises (MNEs)? Multinational Enterprises, commonly referred to as MNEs, are corporations that operate in multiple countries through various subsidiaries, branches, or affiliates. These entities maintain a central management structure while leveraging diverse resources, labour markets, and customer bases across borders. The fundamental aspect that distinguishes MNEs from other corporate forms is their cross-border activity, which can include... More)? Multinational EnterprisesWhat are Multinational Enterprises (MNEs)? Multinational Enterprises, commonly referred to as MNEs, are corporations that operate in multiple countries through various subsidiaries, branches, or affiliates. These entities maintain a central management structure while leveraging diverse resources, labour markets, and customer bases across borders. The fundamental aspect that distinguishes MNEs from other corporate forms is their cross-border activity, which can include... More, commonly referred to as MNEsWhat are Multinational Enterprises (MNEs)? Multinational Enterprises, commonly referred to as MNEs, are corporations that operate in multiple countries through various subsidiaries, branches, or affiliates. These entities maintain a central management structure while leveraging diverse resources, labour markets, and customer bases across borders. The fundamental aspect that distinguishes MNEs from other corporate forms is their cross-border activity, which can include... More, are corporations that operate in multiple countries through various subsidiaries,

ATL-Editor 26 January 2019