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    The International Tax Journal

    The International Tax Journal


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    Author: I/I/T/F Editor

    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)…

    I/I/T/F Editor December 10, 2020

    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…

    I/I/T/F Editor November 18, 2020

    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.…

    I/I/T/F Editor November 16, 2020

    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),…

    I/I/T/F Editor November 12, 2020

    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…

    I/I/T/F Editor November 12, 2020

    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…

    I/I/T/F Editor November 6, 2020

    Tax/TP governance strategies

    Document by: TPAGlobal Click here to download the document:

    I/I/T/F Editor November 2, 2020

    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…

    I/I/T/F Editor October 30, 2020

    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.

    I/I/T/F Editor October 27, 2020

    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…

    I/I/T/F Editor October 21, 2020
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