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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 […]

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South Africa: with effect from 1 April 2014 VAT registration will be required for foreign suppliers of e-commerce services

April 1 2014 South Africa should be added to that list. “The obligation on the foreign supplier to register for Vat arises where the total value of taxable electronic supplies made exceeds R50 000 within a 12 month period.”  see South Africa: with effect from 1 April 2014 VAT registration will be required for foreign suppliers […]

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Update on Africa Tax Dispute successes

Update on Africa Tax Dispute successes Following recent successes in various tax disputes throughout Africa 14 January 2014 We act for various multi-national clients throughout Africa. We are pleased to announce that we now have the following successes on behalf of multi-national clients in Africa, after a recent success against the Rwanda Revenue Authority: Malawi […]

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Research on International Tax Law Guide – by Prof D N Erasmus

Introduction to WTO Basic Principles and Rules - http://etraining.wto.org/admin/files/Course_361/Module_1562/ModuleDocuments/BP-L1-R1-E.pdf   Detailed Presentation of the Dispute Settlement System- http://etraining.wto.org/admin/files/Course_361/Module_1566/ModuleDocuments/DS-L2-R1-E.pdf   Wikipedia – Treaties of South Africa- http://en.wikipedia.org/wiki/Category:Treaties_of_South_Africa   International Telecommunications Regulations- http://www.itu.int/en/wcit-12/Pages/itrs.aspx   UN Multilateral Treaties Deposited with the Secretary-General-http://treaties.un.org/Pages/ParticipationStatus.aspx Vienna Convention on the Law of Treaties http://treaties.un.org/Pages/ViewDetailsIII.aspx?&src=TREATY&mtdsg_no=XXIII~1&chapter=23&Temp=mtdsg3&lang=en NYU ONLINE Research Guide on International Tax Law [[1]]   […]

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SOUTH AFRICA – National Treasury Released Draft Laws By Ministry of Finance

National Treasury Released Draft Laws By Ministry of Finance S.Africa National Treasury released the draft Taxation Laws Amendment Bill and the Tax Administration Laws Amendment Bill, 2013 for public comment BY 1 AUGUST 2013. The LSSA will be making written and oral submissions to National Treasury and Parliament. Group members are kindly requested to review […]

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SOUTH AFRICA Transfer Pricing – Safe Harbour for thin capitalisation

SOUTH AFRICA Transfer Pricing – Safe Harbour for thin capitalisation In a recent media release dated 29 April 2013, SARS have indicated that they are considering the introduction of so-called “safe harbour” provisions in respect of interest paid to non residents. The safe harbour is that interest should not exceed 30% of taxable income.   […]

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Litigation: Sections of Acts declared invalid after warrantless search

Litigation: Sections of Acts declared invalid after warrantless search The Western Cape High Court has declared certain sections of the Estate Agency Affairs Act and the Financial Intelligence Centre Act inconsistent with the Constitution and invalid to the extent that they permit any inspections – whether routine, random or for enforcement purposes – without a […]

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Global International Tax round-up

Some information provided by Basham: In a globalized world, the finance and tax departments of corporations need to be kept informed about current international tax matters. You will find below a brief summary of various developments in international taxation. South Africa: Safe haven rules may be reintroduced to regulate thin capitalization. Australia: The Australian tax […]

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Similar provisions to Tax Admin Act 28 of 2011 – Directors, managers and legal representatives may be held responsible for tax debts of corporate taxpayers

Bolivia Report from IBFD correspondent Carola Jauregui, Grupo Ruizmier Bolivia Directors, managers and legal representatives may be held responsible for tax debts of corporate taxpayers Normative Resolution 10-20-13 of 31 May 2013, published on 2 June 2013 and in force as of that date, regulates article 32 of the National Tax Code concerning the procedure […]

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South African Exchange Control system challenged by Mark Shuttleworth

Pretoria – Billionaire entrepreneur Mark Shuttleworthhas taken the South African government to court to have the country’s exchange control system declared unconstitutional. Shuttleworth also wants the North Gauteng High Court in Pretoria to set aside a levy of over R250m he had to pay to get some of his assets out of the country in 2009, […]

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