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Author: Cramer, Peter

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Tax implications of transfer pricing on supply chain management

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Transfer pricing
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The effect of the Coca-Cola transfer pricing cases and selected shifts in the international tax regime on the determination of an arm's length price
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Value added tax - place of supply and the taxation of the electronic cross border supplies of services and intangibles
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Conversion of shares: the tax implications
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The tax consequences of the transfer of technical reserves between short-term insurers as part of a portfolio transfer
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Value-added tax:Analysis of the supply of cross border electronic services
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The tax deductibility of contingent liabilities transferred in the sale of a going concern
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The implications of wealth transfer taxation in the absence of estate duty
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An evaluation of the Country-by-Country Reporting (CbC Template) for transfer pricing documentation purposes from a South African perspective
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An investigation into the normal tax implications of a carried interest received by fund managers
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Value-Added Tax (VAT) Implications within the South African environment arising from the classification of cryptocurrencies as financial services under the VAT Act
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Is there a divergence between the OECD Transfer Pricing Guidelines and post-BEPS interpretation of the Arm?s Length Principle in OECD materials, with emphasis on the control of risk and value creation?
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Income Tax Penalties and the Doctrine of Punishment
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Whether tax incentives to stimulate foreign direct investment for manufacturing in the SADC region is an indicator of harmful tax competition.
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Tax consequences of the 2010 FIFA World Cup
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Simulation discussed : tax avoidance in the common law
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