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714 articles

S.Africa: A diver’s quandary: The role of domestic law in interpreting double taxation…

Cliffe Dekker Hofmeyr In the international tax law arena, agreements for the avoidance of double taxation (DTAs) are, very simply,

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Nigeria

SSRN Research Papers download – Tax Planning and other Papers to download

SSRN Research Papers Congratulations Dr Daniel N Erasmus You are currently in the top…

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TRANSFER PRICING BUSINESS MODELS

By Angela Sadang | January 27, 2017 | Download PDF Once the initial transfer pricing interviews (i.e. functional analysis interviews) have…

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Nigeria

S.Africa: Win for the employer: Judgment on the Employment Tax Incentive Act

By CDH Cliffe Dekker Hofmeyr – Louis Botha and Louise Kotze In the recent case of ABC (Pty) Ltd v The Commissioner for the

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Global Tax Alert: Dutch Supreme Court confirms dividend withholding tax exemption under treaty…

DLA PIPER In our Global Tax Alert on February 5, 2018, we discussed the decision of the Dutch Court of Appeal (‘s-Hertogenbosch)

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Nigeria

S.Africa: When must a reportable arrangement be disclosed to SARS?

By Ben Strauss, Cliffe Dekker Hofmeyr Attorneys Under the Tax Administration Act, No 28 of 2011 (TAA) persons who enter

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Nigeria

UN tax committee to update to key transfer pricing manual for developing countries

By Julie Martin, Editor, MNE Tax The next edition of the United Nations Practical Manual on Transfer Pricing for Developing Countries will…

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Nigeria

S.Africa: Revenue Service issues interpretation note on headquarter companies

South Africa Report from our correspondent Lutando Mvovo, South Africa Revenue Service issues interpretation note on headquarter companies…

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Nigeria

S.Africa: New VAT regulations for electronic services effective April 2019

New VAT regulations for electronic services effective April 2019 Baker McKenzie – Stephan Spamer and Seelan Moonsamy South Africa November…

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Nigeria

S.Africa: Important judgment on simulation handed down by Supreme Court of Appeal

Important judgment on simulation handed down by Supreme Court of Appeal On 9 November 2018, the South African Supreme Court

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Nigeria

South Africa’s Revenue Service releases updated guidance on seeking mutual agreement procedure…

South Africa’s Revenue Service releases updated guidance on seeking mutual agreement procedure assistance DLA Piper South Africa’s Revenue…

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Nigeria

US: Medtronic TP case – 8th Circuit Court

TPA tech meeting medtronic case The full appeal case is here: US TP Medtronic case 2018 In this edition: the

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Nigeria

S.Africa: New electronic services regulations: Widening the invisible VAT net

New electronic services regulations: Widening the invisible VAT net Cliffe Dekker Hofmeyr Foreign suppliers of e-services are required to…

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Nigeria

S.Africa – Win for mining industry: High Court rules on calculation of royalties

In the recently decided United Manganese of Kalahari (Proprietary) Limited v Commissioner for the South African Revenue Service,(1) United…

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Nigeria

S.Africa – SARS Share Owners Tax Guide

SARS 2018 Tax Guide for Share Owners Revenue Service issues tax guide for share owners On 5 November 2018, the

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Nigeria

Revenue statistics in Africa – 3rd edition

The third edition of Revenue Statistics in Africa, released today in Paris during the 18th International Economic Forum on Africa,

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Nigeria

South Africa: Country-by-country CBC guide by SARS – creating confusion?

Look at the following Guide on CBC by SARS at page 23: SARS 2018 cbc – How to complete and

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Nigeria

More than one way to skin a cat? High Court considers SARS’ power to issue reduced assessments

by Cliffe Dekker Hofmeyr Introduction Under Section 93 of the Tax Administration Act (28/2011), there are five circumstances under which

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Transfer Pricing – 6. Transfer Pricing in the 21st Century: A New Approach to the Arm’s Length…

Transfer Pricing – 6. Transfer Pricing in the 21st Century- A New Approach to the Arm’s Length Principle?

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Nigeria

The Tax Ombud’s Report is in and the results are few. Is the office of the Tax Ombud doing its…

The Tax Ombud’s Report is in and the results are few. Is the office of the Tax Ombud doing its

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Nigeria

Impact of China’s investment on the South African tax base

ENSafrica South Africa October 3 2018 The news that China has committed to invest approximately R200-billion in South Africa was greeted

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Nigeria

Tax returns: when does prescription commence to run?

Introduction Section 99 of the Tax Administration Act (28/2011) addresses the limitation periods for issuing assessments. More…

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Nigeria

Transfer pricing disputes to threaten big companies’ profit growth

Transfer pricing disputes to threaten big companies’ profit growth Postgraduate Diploma in Transfer Pricing | Starts 29 Oct 2018 Transfer…

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Nigeria

S.Africa: When does tax avoidance apply

By ENSAfrica Groups of companies often wish to restructure or rationalise their operations. This generally involves a transfer of companies

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