ITC 13238 & ITC 13164 WCTC (8 December 2014) 17 March 2015 Author: Erich Bell (SAIT Technical) Introduction This case considers an application by SARS…
Posts tagged as “Transfer Pricing”
MIAMI TP CONFERENCE: OBSERVATIONS AT THE TP MINDS TRANSFER PRICING SUMMIT 2015 HELD IN MIAMI ON 24/25 FEBRUARY 2015 The main theme of the Transfer…
Deemed loans under transfer pricing seen as a dividend declared on 1 January 2015 Authors: Okkie Kellerman, Jens Brodbeck and Arnaaz Camay (ENSafrica) South African taxpayers who…
Big brother is watching you! DLA Cliffe Dekker Hofmeyr Lisa Brunton Global, South Africa February 13 2015 Even George Orwell, with his prophetic satirical insight,…
Transfer pricing documentation requirements due to change Hogan Lovells Michiel Els South Africa January 21 2015 The Davis Committee has made certain recommendations…
Proposed Changes to Secondary Transfer Pricing Adjustment South Africa’s National Treasury and the South African Revenue Service (SARS) recently released the draft Taxation Laws Amendment…
Status of transfer pricing in Africa (Part I) ENSafrica Celia Becker Status of transfer pricing in Africa (Part I) Tanzania publicly released its Transfer Pricing…
Transfer Pricing: 25{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e} rule of thumb not applicable to determining royalty rates Attached please find a recent U.S. Court of Appeals for the Federal Circuit…
COMMENT BY DR. D.N. ERASMUS – This is a summary of an article first published in a Bloomberg BNA Transfer Pricing Report available here –…
DLA Cliffe Dekker Hofmeyr Heinrich Louw South Africa September 12 2014 National Treasury and the South African Revenue Service (SARS) recently released the draft Taxation…