S.Africa: Grounds of assessment held to be unreasonable

ATL-Editor 26 June 2019

… the grounds of assessment were unreasonable in two respects, namely the incorrect utilisation of the Net Asset Value (NAV) methodology and the Commissioner’s valuation of the shares as nil:

unreasonable grounds of assessment COMMISSIONER FOR THE SOUTH AFRICAN REVENUE SERVICE v STEPNEY INVESTMENTS (PTY) LTD 78 SATC 86 Download

This judgment is useful for arguing against unreasonable conduct by Revenue agencies when they issue TP assessments without following the 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... More TPGs on methodologies.

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ATL-Editor

Corporate tax planning developments in South Africa

ENSafrica A company is defined in the Income TaxIncome Tax is a direct levy imposed by governments on the income generated by individuals, corporations, and

ATL-Editor 13 November 2019

S.Africa: Summary of the Davis Tax Committee’s BEPS Sub-committee General Report released December 2014

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... More Sub-committee General Report released December 2014 by Peter Dachs of ENS Introduction This note provides a summary of

ATL-Editor 26 February 2015

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Zimbabwe: Recent Zimbabwe Court cases

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

ATL-Editor 16 January 2016

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Portugal vs A Mining SA: Transfer Pricing Case

The case concerns a tax disputeTax Disputes arise when there is a disagreement between taxpayers and tax authorities regarding the interpretation or application of tax laws. These disputes may concern various issues such as the accuracy of a tax return, the eligibility for tax deductions or credits, the correct amount of tax liability, or transfer pricing adjustments. Tax disputes can lead to lengthy legal proceedings... More between A…, S.A., a Portuguese mining company, and AT – Tax and Customs Authority. At the heart of the issue was the sale of an industrial wash plant by A… to B…, S.A., at a symbolic price of €1. AT contended that the sale breached transfer pricingTransfer pricing is a fundamental concept in international taxation that defines the pricing methods and rules applied to transactions between related entities within a multinational enterprise (MNE). In the context of tax regulations, it governs how prices for goods, services, or intangibles (such as intellectual property) are set when these items are exchanged between different branches, subsidiaries, or affiliates of... More principles under Article 58 of the IRC Code.

ATL-Editor 18 November 2024

AFRICA: Sub-Saharan Africa and international arbitration – how does that work?

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

ATL-Editor 29 August 2014

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