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Simple World Map Author: Al MacDonald Editor: Fritz Lekschas License: CC BY-SA 3.0 ID: ISO 3166-1 or "_[a-zA-Z]" if an ISO code is not available
714 articles

Canada: Two fairly recent transfer pricing cases

Cameco Corporation v. The Queen The Tax Court of Canada ruled on Cameco Corporation v. The Queen on 26th September

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S.Africa: Grounds of assessment held to be unreasonable

… the grounds of assessment were unreasonable in two respects, namely the incorrect utilisation of the Net Asset Value (NAV)

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KENYA: The Kenya/Mauritius DTA declared invalid – why?

VI. Conclusion It is astounding to this writer that in the aftermath of the decision in TJN-A v KRA, the

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Malawi: Tax issues – TREASURY FAULTED ON INVESTOR TAX BURDEN

STEVE CHILUNDU Staff Reporter Economists and tax experts have faulted Treasury for introducing tax policies that are not favourable in

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Digest of Important Judgments on Transfer Pricing and International tax – 2018

http://www.fitindia.org/downloads/digest_of_1350_it_and_tp_cases_2018.pdf The Digest contains 1350 important judgments which were…

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ZIMBABWE: Income tax (transfer pricing documentation) regulations 2019 issued

The Minister of Finance and Economic Development issued the Income Tax (Transfer Pricing Documentation) Regulations 2019 by Statutory…

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Mauritius 2019 Budget Speech

The Prime Minister of Mauritius presented the Mauritian Budget Speech for the 2019/20 year yesterday. The important tax proposals, insofar…

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Nigeria

Tax risk management free pdf book

by Dr Daniel N Erasmus PhD EA USTCP Int’l Tax Attorney Tax Risk Management is more relevant than

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TP articles in DTAs being used as “tax charging sections”

Here are the recent cases where the courts have considered whether or not Article 9 Associated Enterprise or it’s equivalent

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TP: A short course in drafting TP related Agreements

Not only is theory important on TP. But how does this translate into practice. Here is a useful short course

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UN TPGs

Here are the latest UN TPGs:…

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Nigeria

Supporting documents to the TP Introduction and Update Seminar

The Continuing Education Questions are at the bottom of this page. Seminar recordings: Lecture 1 –…

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KENYA: High Court ruling on Mauritius treaty

By ENS Africa update – KENYA: High Court ruling on Mauritius treaty On 15 March 2019, The High Court of

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India

Anwar & Co. v. CIT: Understanding Permanent Establishment in International Taxation

The case of Anwar & Co. v. CIT is a landmark ruling by the Supreme Court of India that delves deep into Permanent Establishment (PE) and…

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Nigeria

The IFA MAURITIUS 13th ASIA/AFRICA CONFERENCE 2019

POEM Panel notes: http://iitfconnect.com/wp-content/uploads/2019/05/Poem-Panel-IFA-Mauritius-2019.pptx POEM notes:…

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India: Recent Transfer Pricing cases – over case 900 summaries

Application of Transfer Pricing provisions not against “non-discrimination” clause of DTAA; DCF valuation subsumes goodwill: In the…

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S.Africa: The “Expat Tax” and Financial Emigration

29 April 2019 In the wake of another budget deficit, SARS looks toward South Africans living abroad to help close

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Africa is being left out of the digital tax loop – by Daily Maverick

Google parent company Alphabet reported recently its full-year results for 2018, announcing income of $30-billion off a revenue of…

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Ghana: Pay some tax before filing tax appeal

GHANA: High Court rules that payment of minimum disputed amount is a prerequisite for filing an appeal The Commercial Division

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S.Africa: Country by Country reporting

Country-by-Country Reporting and Transfer Pricing SARS issued a public notice on 20 October 2017 which stipulates the requirements and…

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TP Zambia: Nestle Zambia Trading Ltd v ZRA

Here is a FULL copy of the case. Although there is a useful summary below, read the full case for

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Nigeria

A creature of statute: A decision about the Tax Court’s power to increase understatement…

In the recent judgment of Purlish Holdings (Proprietary) Limited v The Commissioner for the South African Revenue Service (76/18) [2019]

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Nigeria

S.Africa: Your taxpayer rights – Tax Dispute Resolution principles

https://www.linkedin.com/feed/update/urn:li:activity:6511218979674169344/

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S.Africa: 20 February 2019 Budget – tax proposals

Budget speech tax proposals:…

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