Tax Treaty Overrides: A Qualified Defense of U.S. Practice – Reuven S. Avi-Yonah
The ability of some countries to unilaterally change, or “override,” their tax treaties through domestic legislation has frequently been…
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The ability of some countries to unilaterally change, or “override,” their tax treaties through domestic legislation has frequently been…
Read more →The decisions of recent Australian case law relating to the general anti-avoidance regime was cause for concern among the Australian
Read more →Download GAAR AS TAX TREATY OVERRIDE – SLOVAK PERSPECTIVE
Read more →ENSafrica A company is defined in the Income Tax Act, 58 of 1962 (the Income Tax Act) as including any
Read more →OECD consults on “Pillar Two” global minimum tax proposal November 8, 2019 The OECD Secretariat today released a consultation document
Read more →The 2019 edition of the tax policy publication Revenue Statistics in Africa…
Read more →The Inland Revenue document Multinational Enterprises Compliance Focus (2019) focuses on the base erosion and profit shifting (BEPS)…
Read more →Follow the curriculum – Reading: For a useful comparative tool on TP country-by-country, look at: https://www.lexology.com/navigator# and…
Read more →Live tutorial materials: Follow the curriculum – Reading: For a useful comparative tool on TP country-by-country, look at:…
Read more →General background summary reading for a FULL overview of TP, in this order, which should be your ongoing reading during
Read more →In May 2019, the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework) agreed a Programme of Work for Addressing the Tax Challenges of…
Read more →Please see the following document as background reading:…
Read more →TP Judgments in Africa The first Ghana TP case – TP Ghana JUDGMENT IN TAX APPEAL CASE BETWEEN BIERSDORF GH LTD AND THE
Read more →Public Protector v South African Reserve Bank (CCT107/18) [2019] ZACC 29; 2019 (9) BCLR 1113 (CC) (22 July 2019) The issues
Read more →South Africa Report from our correspondent Lutando Mvovo, South Africa Foreign Employment Income Exemption; Frequently Asked Questions…
Read more →Below is a link to the short presentation on the latest Africa TP cases and the experience of Dr. Erasmus
Read more →Here is a list of the current cases: The first Ghana TP case – TP Ghana JUDGMENT IN TAX APPEAL CASE
Read more →Africa Doing Business 2020: Two sub-Saharan African countries among most improved in Ease of Doing Business Economies in sub-Saharan Africa
Read more →As the OECD ventures forth in digital transactions and global minimum tax standards, it is always helpful to keep in
Read more →22 OCT 2019 ENSafrica – Celia Becker ANGOLA: Treaty with Portugal enters into force On 22 August 2019, the Angola-Portugal
Read more →Tax evasion and related financial crime threaten the strategic, political, and economic interests of all countries. Recognising the threat…
Read more →Jonathan Schwarz (Temple Tax Chambers; King’s College London)/October 14, 2019 Some four years ago in this blog, I wrote about problems that
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