SOUTH AFRICA: MY TAKE ON THE 2024 BUDGET SPEECH
The 2024 Budget Speech underscores a commitment to implementing a Global Minimum Tax, aligning with international efforts to curtail tax base erosion …
Category: Dispute Resolution
BOOK UPDATE: “CONDUCTING A TP TRIAL” – CHAPTER 1 NOW AVAILABLE
Having prepared and argued at numerous Transfer Pricing trials, I thought it a good idea to commit my journey and experiences to paper as a guide to o…
Estate Duty in African Nations
Old Ben Franklin said that nothing in the world is certain except death and taxes. Most people find both subjects disagreeable, and generally the tw…
TRYING TO SETTLE TAX DISPUTES OUTSIDE THE PARAMETERS OF TAX LEGISLATION
This reminds me of a recent issue raised by a client MNE in Africa. The taxpayer was facing a revised tax assessment and had to pay 30% of the revised…
Unlocking the Complexities of Tax Dispute Resolution in South Africa:
In the ever-evolving landscape of taxation, the ability to navigate tax disputes effectively is more crucial than ever. I am thrilled to introduce our…
Dispute Resolutions
We’ve honed our skills on dispute resolutions internationally, involving various tax authorities. We have a record of settling for less than 3% of a…
TPMinds Africa: 07 – 08 November 2023
I/I/T/F Head of Academic Development, Prof Dr Daniel N. Erasmus was in attendance at the event and delivered a key-note presentation on:
HOW TO PRE…
Stora Enso Wood Products vs Czechia
The Supreme Administrative Court (SACC) of the Czech Republic annulled the judgment of the Regional Court in Hradec Králové, which had previously an…
Boston Scientific v. CIT (India): Permanent Establishment and TP Implications
This case, heard by the Indian courts, raises significant issues concerning the activities that constitute a PE, especially in relation to multination…
CEPSA’s Transfer Pricing Case: Spain vs Compañía Española de Petróleos (CEPSA)
The Supreme Court ruled on the tax dispute between the Spanish tax authorities and CEPSA concerning the allocation of general management and administr…