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
Summary of the Davis Tax Committee’s BEPSBEPS stands for "Base Erosion and Profit Shifting". BEPS refers to tax avoidance strategies used by multinational enterprises (MNEs) to exploit gaps and mismatches in the international tax system. By shifting profits from high-tax jurisdictions to low- or no-tax locations, MNEs reduce their overall tax burden, even if little to no economic activity occurs in the low-tax jurisdictions. These practices erode... Sub-committee General Report released December 2014 by Peter Dachs of ENS Introduction This note provides a summary of
*For clarity, the term Double Tax TreatyA Double Taxation AgreementA Double Taxation Agreement (DTA), also known as a Double Taxation Treaty (or a Tax Treaty), is an international tax treaty between two or more countries that aims to prevent individuals or businesses from being taxed twice on the same income. With globalisation and the increase in cross-border economic activities, DTAs have become essential tools for promoting trade, investment, and... (DTAA Double Taxation Agreement (DTA), also known as a Double Taxation Treaty (or a Tax Treaty), is an international tax treaty between two or more countries that aims to prevent individuals or businesses from being taxed twice on the same income. With globalisation and the increase in cross-border economic activities, DTAs have become essential tools for promoting trade, investment, and...), also known as a Double TaxationDouble Taxation occurs when the same income or financial transaction is taxed twice, typically in different jurisdictions. It can arise in two primary contexts: economic double taxation, where the same income is taxed twice in the hands of different taxpayers, and juridical double taxation, where the same taxpayer is taxed on the same income in more than one country. Double... Treaty (or a Tax TreatyA Double Taxation Agreement (DTA), also known as a Double Taxation Treaty (or a Tax Treaty), is an international tax treaty between two or more countries that aims to prevent individuals or businesses from being taxed twice on the same income. With globalisation and the increase in cross-border economic activities, DTAs have become essential tools for promoting trade, investment, and...), is an international
Recent Zimbabwe Court cases Comments provided by TaxMatrix (Pvt) Ltd – http://taxmatrix.co.zw/wp-content/uploads/2016/01/December-2015-MTU.pdf Care International- An employee causes a loss to the entity but loss also aggravated
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