TP judgments in Africa – as at Nov 2019

ATL-Editor 30 October 2019

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Here is a list of the current cases:

The first Ghana TP case – TP Ghana JUDGMENT IN TAX APPEAL CASE BETWEEN BIERSDORF GH LTD AND THE COMM GENERA…

The first RSA TP related case – Crookes Brothers Ltd v Commissioner for the South African Revenue Service [2018] ZAGPHC 311 (judgment delivered 8 May 2018)

This is a summary of the above case – Crookes Bros case synopsis-may-2018

The first Malawi TP case – TP MALAWI JUDICIAL REVIEW Eastern Produce (MW) Ltd vs MRA (Transfer Pricing) (Applicability of OEC… (2) delivered July 2018

The first Kenya TP case – Unilever Kenya Ltd v Commissioner KRA Income Tax Appeal 753 of 2003

The first Zimbabwe TP case – relying on the general anti-avoidance provisions to tax notional income that had not been received or accrued as an “amount” – CRS (Pvt) Ltd v Zimbabwe Revenue Authority High Court of Zimbabwe 31 Oct 2017

The first Zambian TP case – http://iitfconnect.com/wp-content/uploads/2019/04/Nestle-vs-ZRA-TP-Case-2019.pdf

The latest Zimbabwe TP judgment:

Judgment in Delta v Zimra Tax appeal Oct 2019Dow
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The firm TRM Daniel Erasmus Tax Court Practitioners is involved in arguing numerous TP cases in Africa – Malawi, Zimbabwe, South Africa and other prospective countries such as Tanzania, Mauritius and Zambia.

In a TP case in Zimbabwe the judgment by Kudya J deviates from his previous judgment in G BANK ZIMBABWE LTD v ZIMBABWE REVENUE AUTHORITY 77 SATC 305 This matter went to trial in Zimbabwe in March 2019 over a period of 3 weeks, and judgment is awaited.

Contact Prof. Dr. Daniel N. Erasmus for more information: daniel@taxriskmanagement.com

Categories: Africa, FP News, Nigeria, SADC, South Africa, West Africa, Zambia

Tags: Courses, Transfer Pricing

ATL-Editor

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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TP Zambia: Nestle Zambia Trading Ltd v ZRA

Here is a FULL copy of the case. Although there is a useful summary below, read the full case for yourself: http://iitfconnect.com/wp-content/uploads/2019/04/Nestle-vs-ZRA-TP-Case-2019.pdf On March 28,

ATL-Editor 1 April 2019

Recent TP Cases

TP Judgments in Africa The first Ghana TP case – TP Ghana JUDGMENT IN TAX APPEAL CASE BETWEEN BIERSDORF GH LTD AND THE COMM GENERA… The first RSA TP case

ATL-Editor 6 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... 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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Understanding Double Tax Treaties: A Comprehensive Guide

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ATL-Editor 28 August 2024

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