Goodbye to the “loop structure” prohibition
BY NICOLETTE SMIT (First published on ENSight) In its typical form, a so-called “loop structure” arises where a South African exchange control resident (individual or company)…
Author: I/I/T/F Editor
SARS NON-COMPLIANCE WITH SECTIONS 42 AND 96 OF THE TAX ADMINISTRATION ACT, 2011
Letter from SAICA to SARS Please find attached SAICA’s submission to SARS regarding SARS’ non-compliance with sections 42 and 96 of the TAA. SARS have…
Allocation issues: Transfer pricing and tax avoidance: just and reasonable solutions?
Article by Jonathan Schwarz (first published on KluwerTaxBlog) When the UK introduced its diverted profits tax, I was telephoned by a lawyer at the US Treasury.…
South Africa Advance Pricing Agreements – Discussion Paper
Published by SARS Multi-national enterprises (MNEs) play important roles around the world and even more so when they invest in developing countries (like South Africa),…
Ghana publishes Transfer Pricing Regulations 2020
Ghana’s Minister of Finance1 submitted new Transfer Pricing Regulations (new Regulations) before Parliament on 10 August 2020. In accordance with Article 11(7) of the Constitution…
GST Input Tax Credit: An Avoidable Controversy
By: Mukesh Butani (BMR Legal Advocates) We are pleased to mail you an Opinion piece as weekend long-read on the subject. The issue on claim…
Key highlights from South Africa’s Minister of Finance 2020 Medium Term Budget Policy Statement
Article by: Regan van Rooy This year certainly continues to be a very interesting year for tax and exchange control. This week, Tito Mboweni, SA’s finance…
First Transfer Pricing Judgment in Nigeria
Article provided by: Financial Regulation International Click below to download the article on Prime Plastichem Nigeria Ltd vs FIRS.
UN tax committee to weigh updates to model treaty, transfer pricing manual
By Julie Martin, Editor, MNE Tax (first published on MNE Tax) The United Nations Committee of Experts on International Cooperation in Tax Matters kicked off its…