South African 2018 Budget Speech

South Africa Report from our correspondent Lutando Mvovo, South Africa Budget for 2018-19 – direct taxation The Budget for 2018-19 was presented to Parliament by the Minister of Finance on 21 February 2018. Details of the Budget with respect to direct taxation, which, unless stated otherwise, will apply from 1 March 2018, are summarized below. […]

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S.Africa: When to expect a transfer pricing interpretation note?

When to expect a transfer pricing interpretation note? 2018/19 South African National Budget Expectations By Billy Joubert, Deloitte. South African corporate taxpayers have, over the past few years, been subjected to a barrage of additional transfer pricing compliance requirements. These have included compulsory documentation requirements, the requirement to submit Country-by-Country (CbC) reports plus onerous additional […]

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S.Africa: Taxpayer wins case against SARS’ failure to issue a Letter of Findings at the conclusion of a tax audit

S.Africa: Taxpayer wins case against SARS’ failure to issue a Letter of Findings at the conclusion of a tax audit I am pleased to inform you that a recent tax case I argued in PE (with colleagues Strombeck Pieterse Attorneys) was won with costs against SARS. The case has been redacted due to it being […]

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US Tax Reform 2018 – GILTI and “deemed transition tax” for US taxpayer individuals and pass-through LLCs

US Tax Reform 2018 – GILTI and “deemed transition tax” for US taxpayer individuals and pass-through LLCs

US 2018 Tax Reform Bill H.R.1 sections 14201 and 14202 on GILTI US 2018 Tax Reform us-tax-reform-context-new-tax-concepts-and-impact-on-your-business-models   A US taxpayer, if you own shares in a foreign company of more than 10% – major repercussions are in play now after the latest US tax reform amendments Published on February 1, 2018 Dr Daniel N […]

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For a road map of where to find key provisions in the final House-Senate bill, read Bloomberg Tax’s analysis.

For a road map of where to find key provisions in the final House-Senate bill, read Bloomberg Tax’s analysis.

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US: Trump Signs Tax Bill, and a Methods-Based Analysis

Trump Signs Tax Bill Lowering Corporate, Individual Rates Posted December 22, 2017, 11:01 A.M. ET By Kaustuv Basu,Laura Davison and Allyson Versprille President Donald Trump signed the Republican tax bill into law, enacting the measure GOP lawmakers are pointing to as their No. 1 achievement during the first year of the administration. The bill (H.R. 1) cuts taxes […]

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Latest new OECD Model Tax Convention 2017 released today – 19 December 2017

OECD Model Tax Convention 2017 The latest edition of the OECD Model Tax Convention has been released today, incorporating significant changes developed under the OECD/G20 project to address base erosion and profit (BEPS). The OECD Model Tax Convention, a model for countries concluding bilateral tax conventions,  plays a crucial role in removing tax related barriers […]

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S.Africa: No trade, no deduction: Tax Court issues Section 11(a) judgment

No trade, no deduction: Tax Court issues Section 11(a) judgment Cliffe Dekker Hofmeyr South Africa December 15 2017 On April 20 2017 the Tax Court issued its decision in X Group (Pty) Ltd v The Commissioner for the South African Revenue Service (SARS).(1) The case concerned X Group’s(2) claim for R90 million as an expense or loss during the 2007 […]

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1. Foreign consultants and services in South Africa 2. The High Court is prepared to hear certain cases

1. Foreign consultants and services in South Africa 2. The High Court is prepared to hear certain cases At TRM Daniel Erasmus Tax Court Practitioners (daniel@TaxRiskManagement.com) we have advocated successfully that the High Court is the correct forum to address certain tax issues, particularly on interpretation and procedural defects, in certain instances. 1. South African […]

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Africa Tax Journal – read for free

www.AfricaTaxJournal.com Enlist at www.ErasmusOnTax.com and subscribe for the FREE eBook on Tax Risk Management a summary of the book Tax Intelligence: The 7 Habitual Mistakes Companies Make available on Amazon.com at: https://www.amazon.com/Tax-Intelligence-Habitual-Mistakes-Companies/dp/145006874X A blog post to listen to the articles is being developed. Future blogs include enlightening blog interviews with key players in Africa Tax. Articles to be published […]

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