I/I/T/F METHODOLOGY = SUCCESSFUL CASES

The BESPOKE-winning methodology that we teach in our Postgraduate course in Transfer Pricing and International taxation has been tried and tested by Dr Daniel N Erasmus in practice.

I/I/T/F has created THE 360 PROJECT, extending the educational platform to assist MNEs in establishing practical and workable systems to identify, monitor and manage the various tax risks that face MNEs.

Click here for more details on THE 360 TRM PROJECT.

This has produced results where just under USD$4bn tax exposures have resulted in less than 3% tax liabilities for clients. 

Below are some of our recent successes using this methodology:

  • Hungary – tax risk management process for MNE based world-wide
  • Ireland/Africa – compile Africa-wide transfer pricing studies
  • Malawi – USD$43m – transfer pricing
  • Malawi – USD$1m Mining industry WHT & VAT – settled, no tax liability after presentations to MRA
  • Mauritius/Africa – compile Africa-wide transfer pricing studies
  • Mauritius – USD$ 200m interest and capex deductions – awaiting judgment
  • Nigeria – review MNE transfer pricing studies
  • Romania – tax risk management process for MNE based world-wide
  • Rwanda  – USD$ approx. 12m – transfer pricing & VAT
  • South Africa – USD$400m – transfer pricing royalty charges – MNE operations in Africa, Asia, Middle-East and Europe
  • South Africa – USD$80m – transfer pricing royalty charges/legal & economic ownership
  • South Africa – USD$60m – customs/excise – liquor industry classification dispute
  • South Africa – USD10m – SARS back-dating revised assessment – on appeal to tax court
  • South Africa – USD$30m – VAT apportionment of input tax credits
  • South Africa – search & seizure warrant & tax audit/investigation
  • South Africa – compile Africa-wide transfer pricing studies
  • Tanzania – USD$ 20m PE issues in technology industry – awaiting judgment
  • Uganda – USD$54m – transfer pricing management fees & capital v revenue deductions
  • US – USD$30m – advice on no tax residency in US to eliminate exit tax
  • US – advice on no tax residency in US for CEO of UAE royal family owned operation
  • US – advice & representation on late FBAR filings and IRS Offshore Voluntary Disclosure Program
  • US – advice to US tax practitioners as specialist on OIC, EITC, late FBAR/PFIC/Form 5471/Form 8840 filings
  • US – tax court petitions – failure to file/arrear taxes – Canadian doctor & citizen
  • US – advice on tax court petition – Schedule C landscaping business deductions
  • US/Africa – USD$100m – advice & structuring on foreign trust/corporation connection to US/Africa tax resident, receiving gift – ongoing
  • US/Africa – disinvestment from Africa operations – tax implications – controversy International Tax & State Responsibility relief
  • Zambia – USD$55m – exit tax/lien
  • Zambia  – USD$approx. 10m – transfer pricing dispute in the manufacturing sector
  • Zimbabwe – USD$20m – transfer pricing agricultural industry
  • Zimbabwe – USD$ extensive, being calculated for 21 subsidiaries – Management fees for large conglomerate – currently being argued
  • Zimbabwe – USD$5m Tobacco industry VAT – awaiting judgment

We pride ourselves in giving the highest degree of professional service to individuals, businesses, corporations, and MNEs (together with their usual advisors) on domestic and international planning, tax audit and tax litigation issues. Our successes are clear – and we DO NOT often go to court. We usually settle matters favourably for clients.

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