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.…
Tag: tax avoidance
The relationship between treaties and domestic anti-abuse provisions
Article by: Jonathan Schwarz (Temple Tax Chambers; King’s College London) – First published on KluwerTaxBlog In last month’s blog I promised to address the treaty…
Tax planning: walking the thin line between tax avoidance and tax evasion
Article by: Ayooluwatunwase Fadeyi Introduction Tax is a mandatory financial charge imposed on taxpayers by the Government as required by statute or other basis, irrespective…
The eye of the needle: Is one of your purposes tax avoidance?
Article by Jonathan Schwarz, first published on http://kluwertaxblog.com/. We have all become familiar with the expression in the PPT set out in article 7(1) of…
SARS will now use artificial intelligence to make ‘it hard and costly’ to dodge tax
Article by: James de Villiers Sars said it would, therefore, hire several executives in data-driven positions to harness the advances in big data and artificial…
A Critical Analysis of Tax Avoidance in theSouth African Income Tax Act 58 of 1962, as Amended
Paper by: Jean Chrysostome Kanamugire “Tax avoidance connotes stratagems which are prima facie lawful, i.e. which are lawful unless expressly proscribed by the Act.”1 Many…
Fraudulent Financial Reporting and Companies’ Characteristics: Evidence from Tax Audit
Paper by: Norsiah Ahmad, Juahir Mohd-Nor and Norman Mohd-Saleh Fraudulent financial reporting has become an important issue in accounting profession. The implementation of self assessment…
S.Africa: Landmark judgment in Supreme Court of Appeal upholds deferred delivery share scheme
Landmark judgment in Supreme Court of Appeal upholds deferred delivery share scheme Commissioner SARS v Bosch (394/2013) [2014] ZASCA 171 (19 November 2014)Share option scheme – s 8A(1)(a) of the Income Tax Act 58 of 1962…