TP Lecture week 17 – Intangibles Part III

ATL-Editor 18 April 2018

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Pre-recorded lecture – Intangibles Part III

https://www.dropbox.com/sh/59apue4obuzukzu/AADVjeq43a9zjs27YccjL24xa?dl=0

Lecture slides and additional reading required:

Lecture 17 ppt

revised-guidance-on-the-application-of-the-transactional-profit-split-method-beps-action-10-2

guidance-for-tax-administrations-on-the-application-of-the-approach-to-hard-to-value-intangibles-BEPS-action-8

Follow curriculum – Reading:

OECD TPG Transfer Pricing Guidelines for Multinational Enterprises and Tax Administration July 2017

Chapter VI

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... Action 8 Hard to value intangibles, page 63 to 117

Intangibles, Risks & Capital, High-Risk Transactions

http://www.oecd.org/ctp/beps-actions.htm

BEPS summary of ACTIONS 8 – 10 New – OECD Development and enhancement of marketing intangibles

General ongoing reading as the courses advance, reading about 10 pages a week to gain an overview understanding: An Overview of Transfer Pricing by IBFD

Start your Assignment 3 preparation now – start reading the EXTENSIVE DOCUMENTS: the pre-trial filing of Coca-cola to the US tax court, and the long list of supporting articles, and start summarizing the case using the principles in 1 Reading cases SSRN-id1160925 This may appear as a key exam question as well.

The coca-cola case pre-trial document and articles can be found here: http://iitfconnect.com/?p=675

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

Tags: Courses, transfer pricing

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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

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ATL-Editor 27 April 2015

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Understanding Double Tax Treaties: A Comprehensive Guide

*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

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IT Lecture week 2, 3, 4 and 5 – Principles of International Tax law

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ATL-Editor 18 April 2018

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