Channels :: FRELIP Discovery

Author: Hattingh, Johann

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An evaluation of the Country-by-Country Reporting (CbC Template) for transfer pricing documentation purposes from a South African perspective

Similar Items: An evaluation of the Country-by-Country Reporting (CbC Template) for transfer pricing documentation purposes from a South African perspective

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Transfer pricing
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Tax implications of transfer pricing on supply chain management
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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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The influence of taxation on mining activities in developing countries - an African perspective
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Analysis of cryptocurrency verification challenges faced by the South African Revenue Service and tax authorities in other BRICS countries and whether SARS’ powers to gather information relating to cryptocurrency transactions are on par with those of other BRICS countries
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Adaptive market hypothesis: insights from BRIC-T countries’ stock markets
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Implications of tax reform in selected countries for taxation of income in agriculture
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Defining a royalty from a South African perspective for the purposes of the South African Income Tax Act and the South African application of its Double Tax Treaty network
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Use of and variance from the United Nations model tax treaty clauses for tax treaties concluded by a group of Southern African Development Community Countries
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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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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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An in depth analysis of the development of the taxation of co-operatives in South Africa and whether this aligns with their economic purpose.
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The implications of wealth transfer taxation in the absence of estate duty
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Characterisation for treaty purposes of manufactured dividends received in terms of securities lending arrangements
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Africa and the taxation of permanent establishments: Is the definition of "permanent establishment" as used in the double tax agreements of selected 'fishing rich' African countries sufficient to protect the taxing rights on those diminishing natural resources?
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The impact of ethics on tax compliance behaviour in developing countries
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The tax deductibility of contingent liabilities transferred in the sale of a going concern
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A comparative analysis of the meaning of 'mining operations' for income tax purposes
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Effects of eurozone and schengen area accession on real estate prices
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A critical analysis of whether the current legislated exit tax provisions of South Africa are proportional to the legitimate purpose of those provisions
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The tax consequences for a seller (also briefly commenting from the perspective of the purchaser) when contingent liabilities are transferred in a sale of a business as a going concern with specific reference and evaluating income tax case no. 1839 : (South Gauteng Tax Court)
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The effect and application of section 8C in respect of the Private Equity Industry
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Tackling international tax avoidance: If South Africa has general anti-avoidance rules, why does it need the principal purpose test?
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The long arm provisions of capital gain tax: An analysis of the capital gains tax consequences on the indirect disposal of immovable property by non-residents in selected African Countries