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Announcing the graduation of Dr. Daniel Erasmus




SOUTH AFRICA 2014 BUDGET SPEECH SUMMARY by www.Bravura.net     BUDGET SPEECH A Budget Speech but a few months before a national election had the potential to surprise in many respects, with much speculation in the press of late as to the potential for tax increases in the context of a still struggling economy. This […]


Why a letter of engagement is necessary at the commencement of a SARS audit

In a recent Court US Judgment set out below the Court found it necessary for an IRS examining agent to testify why they were summonsing certain documentation from a taxpayer in the course of an Audit.  Although the provisions in South African legislation are different to those in the US Tax Legislation the concepts are […]


FATCA – And its effect on offshore trusts – a due diligence on FATCA compliance may be required for your non-US business where you have US clients

In order to discuss the impact of the proposed changes, it is important to understand the existing legislative structure applying to offshore trusts. What follows is a brief summary of the existing U.S. rules applicable to the taxation of offshore trusts. If a foreign trust is funded by a U.S. person and has a U.S. […]


TP – discussion draft includes a “Model Template of Country-by-Country Reporting” for a multinational enterprise

Jan. 30 — The Organization for Economic Cooperation and Development has released a milestone discussion draft that would require companies for the first time to complete a template providing tax administrations with exhaustive details of how they allocate their income, taxes and business activities on a country-by-country basis. Draft Template The Jan. 30 discussion draft includes […]


Malawi: Transfer Pricing Audit

The TRM team have recently advised and assisted a large MNE in interdicting the Malawi Revenue Authority from executing a faulty revised tax assessment based on unlawfully obtained documentation. The documentation was not obtained through formal Exchange of Information channels in terms of the appropriate DTA’s. TRM also assisted the MNE filing the Appeal to […]


The Top 50 Tax Payers in South Africa & TRM™ Services

In a recent tax survey by a Big 4 Firm, the list of participants noted as the 50 biggest corporate taxpayers in South Africa were listed (see full list below): TRM™ Services has either acted for and/ or educated at least 40% of the companies on this list (highlighted). For more information about our services […]


Survey of Developments – US Tax Related Reporting (Prof. William Byrnes at SAIT Conf.)

by Prof. William Byrnes. Associate Dean International Tax & Financial Services, Thomas Jefferson School of Law, San Diego, California (USA) Prof. William Byrnes delivered this paper at the South African Institute of Tax Practitioners’ Annual Tax Conference on 13 October 2010. Survey Topics Qualified Intermediary Regime (before and after UBS) (QI); Foreign Account Tax Compliance […]


RSA: Urgent Interdict Against SARS for failing to issue valid letter of findings

TRM™ is pleased to announce that it successfully represented one of the largest mining groups in the world in an urgent application again SARS in terms of which application the taxpayer sought an interdict against SARS blocking it from issuing quick revised assessments just before the prescription of the statute the three-year term under circumstances […]


KENYA: Transfer Pricing Audit

TRM™ announces that it is involved in advising a major multinational in a transfer pricing audit taking place in Kenya. The key documentation to transfer pricing in Kenya includes reference to articles 2(4) and 47 of the Kenyan Constitution, read together with the Income Tax Transfer Pricing Rules, 2006, and section 18 of the Kenyan […]

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