Looking at it from a S.African perspective: Transfer pricing review and adjustments in the USA
NOTE FROM PROF. DR. DANIEL N. ERASMUS: The key part of the article below is the following, which speaks to the situation in South Africa
Category: South Africa
Malawi tax collector loses TP case against Eastern Produce
Malawi tax collector loses case against Eastern Produce For a copy of the judgment: https://www.dropbox.com/sh/8v1vx14n3hrgky4/AABzcqbi3yExqT14DGRqylDNa?dl=0 BY FESTON MALEKEZO: The High Court in Blantyre has ruled in
Analyzing Value Chains in Business Models Impacted by the Digital Economy
Analyzing Value Chains in Business Models Impacted by the Digital Economy Digitization has given rise to new firms and industries, besides altering the traditional business models
Information referred to in a presentation to MNEs
Tax Intelligence book I wrote a book on tax riskTax Risk refers to the uncertainty surrounding the potential financial or reputational impact of tax-related decisions and events on a business or individual. This risk arises due to various factors, such as complex tax regulations, inconsistent tax authority interpretations, or evolving international tax laws. Effective tax risk management involves identifying, assessing, and mitigating potential tax-related threats to prevent financial penalties,... managementTax risk management is a structured process used by organizations, particularly 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... (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...), to
S.Africa: SARS new MAP Guide – Final
http://www.sars.gov.za/AllDocs/OpsDocs/Guides/LAPD-IT-G24{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20-{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Guide{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20on{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Mutual{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Agreement{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e}20Procedures.pdf South Africa Report from Prof. Johann Hattingh, University of Cape Town Revenue ServiceTax 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..., collection,
S. Africa: CAN THE COURTS MAKE USE OF SARS INTERPRETATION NOTES IN INTERPRETING LEGISLATION?
CAN THE COURTS MAKE USE OF 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... INTERPRETATION NOTES IN INTERPRETING LEGISLATION? 25 Jul 2018 by PKF Durban In the recent case of Marshall N.O. and
Various Constitutions and why they are important in tax
SOURCE: of Constitutions of various Countries http://www.wipo.int/wipolex/en/ The above link not only introduces you to various treaties and laws per country on IPIntellectual Property (IPIntellectual Property (IP) refers to creations of the mind, including inventions, literary and artistic works, symbols, names, images, and designs used in commerce. It grants creators exclusive legal rights to use and exploit their work, ensuring protection against unauthorised use or reproduction. These rights are critical in fostering innovation and creativity while providing economic value to individuals and organisations. IP...)
Update on the Tax Dispute Resolution Process – 26 June 2018
This online seminar is presented by Prof. Dr. Daniel N. Erasmus and Schalk Pieterse, both experienced practitioners in this field. The 2 have worked together
South Africa: Controlled Foreign Companies (CFC’s)
By ENS Section 9D of the Income TaxIncome Tax is a direct levy imposed by governments on the income generated by individuals, corporations, and other
The OECD released two reports containing Guidance for Tax Administrations on the Application of the Approach to Hard-to-Value Intangibles, under BEPS Action 8; and Revised Guidance on the Application of the Transactional Profit Split Method, under BEPS Action 10
The OECDThe Organisation for Economic Co-operation and DevelopmentThe Organisation for Economic Co-operation and Development (OECD) is an international organisation comprising 38 member countries, established to foster economic growth, trade, and development on a global scale. Founded in 1961, the OECD provides a forum for governments to collaborate, share policy experiences, and develop solutions to common economic challenges. The OECD's core mission is to promote policies that improve... (OECDThe Organisation for Economic Co-operation and Development (OECD) is an international organisation comprising 38 member countries, established to foster economic growth, trade, and development on a global scale. Founded in 1961, the OECD provides a forum for governments to collaborate, share policy experiences, and develop solutions to common economic challenges. The OECD's core mission is to promote policies that improve...) is an international organisation comprising 38 member countries, established to foster economic growth, trade, and development