transfer pricing Archives - Page 6 of 21

SARS is circulating a section 46 of the Tax Administration Act, 2011 request for relevant material to many multinationals requesting information about their intra-group services.

Article by: Dr Daniel N Erasmus (Pieterse TRM Erasmus Tax Attorneys) SARSThe 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... (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...) is the official tax authorityTax authorities are fundamental institutions within government frameworks, overseeing tax assessment, collection, and administration. Their operations ensure that tax laws are enforced and public funds are collected efficiently. This article delves into tax authorities' purpose, responsibilities, and structure, offering insights into their essential role in supporting government functions and economic stability. What is a Tax Authority? A tax authority is... responsible for the

ATL-Editor 19 February 2020

Transfer pricing methods in Greece

Article by: Fotodotis Malamas (Bernitsas Law) Accepted methods What transfer pricingTransfer pricing is a fundamental concept in international taxationFOR MORE INSIGHT ON INTERNATIONAL TAXATION, PLEASE READ THIS ARTICLE: Introduction to International Taxation: Key Concepts & Guidelines International Taxation encompasses the framework of laws, principles, and treaties that govern the tax obligations of individuals and entities engaged in economic activities that span multiple jurisdictions. This field addresses how income, profits, and gains are taxed when operations or investments extend... that defines the pricing methods and

ATL-Editor 18 February 2020

Transfer pricing in a nutshell: Israel

Article by: Eyal Bar-Zvi (Herzog Fox & Neeman) Overview Israel’s transfer pricingTransfer pricing is a fundamental concept in international taxationFOR MORE INSIGHT ON INTERNATIONAL TAXATION, PLEASE READ THIS ARTICLE: Introduction to International Taxation: Key Concepts & Guidelines International Taxation encompasses the framework of laws, principles, and treaties that govern the tax obligations of individuals and entities engaged in economic activities that span multiple jurisdictions. This field addresses how income, profits, and gains are taxed when operations or investments extend... that defines the pricing methods

ATL-Editor 18 February 2020

Transfer Pricing Guidance on Financial Transactions

INCLUSIVE FRAMEWORK ON BEPSBEPS stands for “Base Erosion and Profit Shifting”. BEPS refers to tax avoidanceTax avoidance refers to the practice of legally structuring financial activities to minimise tax liability, reducing the amount of tax owed without violating laws. Unlike tax evasion, which is illegal and involves concealing income or misreporting, tax avoidance operates within the framework of the law. Multinational enterprises (MNEs) and individuals often engage in tax planning strategies that reduce tax liabilities... strategies used by 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 exploit gaps and

ATL-Editor 18 February 2020

How the Israel tax authorities are interpreting intergroup intangibles exports – ISRAEL TP CASE

Article by Henriette Fuchs (Pearl Cohen Zedek Latzer Baratz) Unlike the taxing authorities in many other countries, the tax authorities of Israel – managing the

ATL-Editor 8 December 2019

THE UTILITY OF ADVANCE PRICING AGREEMENTS (APAs)

Paper by: Olamide Akinla Nigeria introduced Transfer PricingTransfer pricing is a fundamental concept in international taxationFOR MORE INSIGHT ON INTERNATIONAL TAXATION, PLEASE READ THIS ARTICLE: Introduction to International Taxation: Key Concepts & Guidelines International Taxation encompasses the framework of laws, principles, and treaties that govern the tax obligations of individuals and entities engaged in economic activities that span multiple jurisdictions. This field addresses how income, profits, and gains are taxed when operations or investments extend... that defines the pricing methods and rules applied to

ATL-Editor 1 December 2019

TP Lecture week 2.2 – Legal Framework

Follow the curriculum – Reading: For a useful comparative tool on TP country-by-country, look at: https://www.lexology.com/navigator# and select the topic “transfer pricing” PWC International TP 2015-16 Kenya, page

ATL-Editor 10 November 2019

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TP Lecture week 2.1 – Legal Framework

Live tutorial materials: Follow the curriculum – Reading: For a useful comparative tool on TP country-by-country, look at: https://www.lexology.com/navigator# and select the topic “transfer pricing” Victor Thuronyi Comparative

ATL-Editor 10 November 2019

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TP Lecture week 1 – TP Legal Framework

General background summary reading for a FULL overview of TP, in this order, which should be your ongoing reading during this course: 6 Chapter Transfer

ATL-Editor 10 November 2019

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