South Africa–MNE Tax

Africa

South Africa’s R&D Catch-22: Lydia Clowney / CrossBorder Solutions→

April 6, 2022

Africa

EU tax transparency directive: When turkeys vote for Christmas

January 10, 2022

Cédric Maheo, CWA Morocco, discusses how the EU directive on public country-by-country reporting for large multinationals, published in the Official Journal of the European Union on December 1, will give tax authorities in the developing world new data on multinationals operating in . . .

Africa

South Africa to reevaluate R&D tax incentive’s continuation, design

December 30, 2021

The South African National Treasury is seeking input on a discussion document released December 15 reviewing the design, implementation, and impact of its research and development (R&D) tax incentive program to determine if the country’s R&D tax regime, which is slated to sunset . . .

Africa

South Africa proposes model legislation to introduce APA program

December 16, 2021

The South African Revenue Service (SARS) on December 10 published a high-level model and draft legislation for the introduction of an advance pricing agreement (APA) program, and plans to launch a pilot . . .

Africa

OECD updates and expands transfer pricing country profiles

December 13, 2021

The OECD today released updated transfer pricing country profiles for 21 countries, including three countries for which it has not previously published profiles: Albania, Kenya, and . . .

Africa

Global tax deal to proceed with G20 endorsement, but not all is resolved

November 1, 2021

At the end of their October 30–31 summit in Rome, the leaders of the G20 adopted a declaration supporting the implementation of new international tax rules – urging the OECD “to swiftly develop the model rules and multilateral instruments” necessary to . . .

Africa

G-24 warns that global tax deal will fail without better terms for developing countries

September 21, 2021

An international tax agreement on new profit allocation rules and a minimum tax will “not be sustainable even in the medium run” unless the terms allow developing countries to see fair shares under both pillars of the deal, the G-24 contended in September 19 comments submitted . . .

Africa

South Africa seeking to amend tax treaties with Germany, Switzerland, and Eswatini to crack down on tax avoidance and boost tax information exchange: Lameez Omarjee / Fin24→

September 3, 2021

Africa

Most favored nation clauses in tax treaties between high- and lower-income countries operate to the disadvantage of the latter, resulting in significant tax base erosion: Deepak Kapoor / ICTD→

August 26, 2021

Accounting

South African tax bill would amend rules on interest deductibility, assessed losses

August 2, 2021

On July 28, the South African Revenue Service and National Treasury released various draft tax bills that would enhance the rules relating to the limitation on interest deductions on payments to persons not subject to tax and would restrict the set-off of the

Africa

Ireland, Lithuania, Hungary offer lowest tax rates for R&D, OECD study finds

August 2, 2021

An OECD taxation working paper on corporate effective tax rates for research and development (R&D) released on July 29 reports that the effective average tax rate on R&D investments in Ireland, Lithuania, and Hungary range from -2% to -4% – suggesting . . .

Africa

Tax dispute peer reviews find Argentine, South African APA programs wanting, Indian MAP issues

July 27, 2021

The latest peer review assessments of countries’ efforts to meet the minimum standard for tax dispute resolution, released by the OECD on July 26, report that both Argentina and South Africa fail the first prong regarding preventing . . .

Antigua and Barbuda

Antigua and Barbuda, Argentina, Russia, South Africa, and Ukraine make progress on meeting international standard on tax transparency and exchange of information in latest peer reviews: OECD→

June 24, 2021

Africa

G20 draft communique reportedly endorses global minimum tax

June 22, 2021

A draft communique for the upcoming G20 finance ministers meeting on July 9–10 includes language expressing the countries’ support for a global minimum tax and new rules . . .

Germany

Indonesian, Mexican, South African finance ministers join German, US counterparts in op-ed endorsing global minimum tax of at least 15%: Arturo Herrera Gutiérrez, Sri Mulyani Indrawati, Tito Mboweni, Olaf Scholz and Janet L. Yellen / Washington Post→

June 10, 2021

Africa

South Africa guidance addresses taxation of foreign dividends other than dividends paid by a headquarters company: South Africa Revenue Service→

May 25, 2021

Africa

South African tax guidance explains withholding rules on interest, royalties

May 19, 2021

The South African Revenue Service has issued guidance clarifying the application of withholding tax provisions applicable to interest and royalties in two interpretation notes . . .

Africa

UN updates transfer pricing manual for developing countries

April 28, 2021

The United Nations’ latest edition of its practical manual on transfer pricing for developing countries, released April 27, adds new content on financial transactions . . .

South Africa High Court rules on its power to review tax authority actions

March 30, 2021

Prenisha Govender of Baker McKenzie, Johannesburg, discusses a March 11 High Court of South Africa judgment that addresses access to the courts in tax disputes . . .

Africa

South Africa issues private ruling on taxation of transfer of reinsurance business from a resident company to a local branch of a foreign company: South African Revenue Service→

March 16, 2021

Africa

South Africa prevails with a TNMM analysis in transfer pricing dispute, but should it have?

February 17, 2021

New York City economist, Dr. J. Harold McClure, discusses South Africa’s win in a transfer pricing dispute with a catalytic converter manufacturer in ABC (Pty) Ltd. v. Commissioner . . .

Africa

South Africa invites public comment on advance tax ruling process: South Africa Revenue Service→

January 19, 2021

Africa

OECD publishes details on 40 countries’ uptake of transfer pricing rules for hard-to-value intangibles

December 16, 2020

The OECD today published 40 responses to a questionnaire that asked officials whether their country has adopted transfer pricing rules for . . .

Africa

Cross-border tax disputes continued to rise in 2019, new OECD stats say

November 18, 2020

Despite the efforts of the OECD and others enhance tax certainty, the number of new tax disputes between multinational groups . . .

Africa

South Africa considers advance pricing agreement program

November 17, 2020

The South African Revenue Service on November 11 published a discussion paper seeking public feedback . . .

Africa

South Africa extends deadlines to file country-by-country reports: South African Revenue Service→

November 13, 2020

Africa

South Africa presidential commission recommends adoption of digital tax, tax on processed metals, R&D tax credit incentive: Businesstech→

October 27, 2020

Americas

OECD publishes report on tax policy reforms enacted both before and after COVID-19 in 37 OECD member countries plus Argentina, China, Indonesia, South Africa: OECD→

September 4, 2020

Africa

South Africa provides assistance to small businesses and employees through tax system

March 24, 2020

Jana Botha, a consultant in the tax practice at Baker McKenzie Johannesburg, discusses tax measures announced on March 23 by South Africa’s government aimed at supporting individuals and small businesses amid the coronavirus emergency . . .

Africa

South Africa 2020 Budget proposes new limits on interest deductions, loss carry-forwards

March 4, 2020

Virusha Subban, Jana Botha, and Prenisha Govender of Baker McKenzie, Johannesburg, discuss South Africa’s 2020 budget, released last week, which announces government proposals to alter the tax rules affecting multinational groups . . .

Africa

BRICS countries look forward to further progress on two-pillar approach to address digitalization: BRICS Information Centre→

November 18, 2019

Africa

OECD report discusses tax reform, trends in OECD countries and Argentina, Indonesia, South Africa: OECD→

September 7, 2019

Africa

South Africa proposes more refinements to anti-dividend stripping rules

June 20, 2019

Emil Brincker of Cliffe Dekker Hofmeyr Inc. discusses South Africa draft legislation released June 10 that is designed to further strengthen the recently introduced anti-dividend stripping rules . . .

Africa

Switzerland to exchange financial account information with 33 more countries for tax purposes

August 15, 2019

Davide Anghileri of the University of Lausanne discusses an August 14 decision of Switzerland’s Federal Council confirming that Switzerland will exchange financial account information with 33 more reviewed partner countries . . .

Africa

South Africa to introduce carbon tax on June 1: Tsvetana Paraskova / OilPrice.com→

May 30, 2019

Africa

First Look: South Africa publishes draft taxation laws

June 18, 2019

The South African government today published portions of the draft Taxation . . .

Africa

South Africa publishes draft tax bills

July 18, 2018

South Africa’s National Treasury on July 17 published the 2018 Draft Taxation Laws Amendment Bill and 2018 Draft Tax Administration Laws Amendment Bill for public comment. The proposed . . .

Africa

South Africa releases guide on resolving cross-border tax disputes

May 23, 2018

The South African Revenue Service (SARS) has produced a draft guide on the mutual agreement procedure(MAP) which allows the . . .

Africa

South African Revenue to revive large business unit

August 24, 2018

The South African Revenue Service (SARS) today announced it will revive its . . .

Khaled Al Zaabi on Spanish government proposes digital services tax: “We are seeking assistance with Digital Assets and International Tax Consulting to help Abu Dhabi UAE Oil Company navigate the…” October 24 ,2024

Emma Hinson Sims on The Pillar One blueprint — the potential future of international taxation and transfer pricing: “HAPPY BIRTHDAY TO A VERY SMART, BEAUTIFUL, YOUNG LADY ON JANUARY 13TH.” January 6 ,2024

David Valdez on US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure: “Greetings Whirlpool Mexico, I’m trying to contact someone involved with the decision making for transportation from all of your Mexican…” October 20 ,2023

Jose Dominguez on The new US international tax rules: what you need to know about GILTI, FDII, BEAT etc.: “Very informative article. Question. Do you have a software to compute these US International Calcs to make them in house?” April 12 ,2023

Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms Susi, This article is immensely clarifying. I’d like to know whether Danish Supreme Court has already granted its…” March 24 ,2023

May 19 – 20	Tax Council Policy Institute Conference	Washington, D.C.
May 19 – 20	IFA Second European Region Conference	Milan, Italy
May 24	IFA Webinar Series Pillar Two: An Update	Virtual Event
Sept. 4 – 8	IFA Congress	Berlin