The facts are set out here:
The moot judgment:
Disputes Mauritius Legit Expect judgment
The supporting documents:
TP SARS Practice Note 7 Income Tax Practice Note 7 of 1999
SARS arguments Legitimate Expectation note
OECD How Acquiescence and Estoppel legally bound to OECD commentaries by Frank Engelen
Unilever Kenya Ltd v Commissioner KRA Income Tax Appeal 753 of 2003
Lecture 2: IT Lecture 2 summary of principles of international tax IT course 2018 Lecture 2 slide notes Unfortunately there was a problem with the
COMMENT Tax arbitration via new double tax treaties is on the increase. Hence, knowledge of international arbitration is important. Take a look at the following
The Tax Appeals Tribunal in Kenya ruled on the case involving AVIC International Beijing (EA) Limited (Appellant) and the Commissioner of Domestic Taxes (Respondent) concerning disputed tax assessmentsA 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 covering Corporation TaxCorporate Tax refers to the tax imposed by governments on the income or capital of corporations. Corporations, considered separate legal entities, are taxed on their profits, meaning the income generated from their operational activities, investments, and other financial undertakings. This tax is generally a key revenue source for governments, helping to fund public services, infrastructure, and other essential functions. The... More, PAYE, and Withholding Tax (WHT) for the years 2016 to 2023.
In the matter of F Taxpayer v 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, the Tax Court of South Africa was tasked with evaluating the procedural compliance and statutory adherence of the 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) in the taxpayer’s appeal concerning assessments for the 2016 to 2018 tax years.
Impact of FATCA on Mauritius Entities Stephen V. Scali Conyers Dill & Pearman Stephen V. Scali is Head of Mauritius Office at Conyers Dill &
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