CATEGORIES
- (1) Negotiating Tax Debt and Payment Arrangements with SARS
- (31)Accounting
- (2)Accounting for Income Tax
- (1)Accounting for Income Tax
- (7)Administration of Estates
- (1)Advisory Services
- (1)Application of tax rates, s6(2) rebates
- (1)Assessed losses
- (4)Audit, Reviews & Other Services
- (9)Blogs
- (8)Capital Gains Tax
- (1)Capital Gains Tax - Individuals Tax
- (1)Capital Gains Tax Implications of Trusts
- (2)Case study: Home office expense
- (1)Case study: Travel allowances
- (1)Company Formations
- (1)Compliance
- (123)Corporate Tax
- (9)Customs and Excise
- (2)Deceased Estate
- (1)Deductions Pre-trade and prepaid expenses
- (1)Deregistration
- (2)Employer and Employee (PAYE and UIF Specific)
- (1)Estate Duty
- (1)Events / Webinars
- (9)Faculty News
- (2)Farming
- (152)Individuals Tax
- (1)Input - Customs Duty
- (3)Interest
- (13)International Tax
- (17)Legislation
- (1)Low interest rate loans and loan subsidies
- (1)Nature of the rights of beneficiaries
- (1)Notional input tax
- (9)Payroll
- (2)Practical Payroll
- (2)Provisional tax (Link with other Taxes)
- (2)SARS Dispute Resolution
- (4)SARS Issues
- (1)Salaried Employees
- (134)Tax Administration
- (2)Tax Administration Part 2B: Resolving Problems with SARS using the Tax Ombud
- (1)Tax Administration Part 3B Dispute Resolution - Objection and appeal
- (3)Tax Update
- (1)Tax implications of loans to trusts
- (1)Tax residence
- (1)Tax returns and payments
- (2)Transfer-Pricing
- (1)Trust Income / Gain Allocations
- (1)Trust types and income allocations
- (6)Trusts
- (70)VAT
- (3)VAT periods
- (1)Wear and tear allowances
- (1)Wills, Estates & Trusts
- (1)Zero Rated
- (1)eFiling
- Show All
Weekly transfer pricing roundup – 26 June 2017
- 26 June 2017
- Corporate Tax
- Marcus
Important:
This article is based on tax law for the tax year ending 28 February 2018.
Author: Marcus
What a busy week it has been with the third meeting on the Inclusive Framework on BEPS, including the release of some new draft reports. Furthermore, the final version of the toolkit addressing the lack of comparables was released. Lastly, FERMA provided draft guidance to the OECD on captive (re)insurance. Not that there wasnt enough reading material already.
Before going into more detail, I wanted to touch base on the picture. The search term “BEPS” is used now more often in Google searches than “transfer pricing.” It just shows how everything has shifted from a transfer pricing only world to a BEPS and value creation world. Another interesting, yet maybe not as academic observation, is that people stop searching for transfer pricing over Christmas, which doesn’t seem to be true for BEPS. But let’s get back to the transfer pricing roundup (or maybe I should call it a BEPS roundup?).
The OECD states that over 200 delegates from 83 countries and jurisdictions as well as 12 international and regional organisations met in Noordvijk, the Netherlands for the Third Meeting of the Inclusive Framework on BEPS. The meeting welcomed Vietnam as its newest and 100th member and discussed and approved its first monitoring report. The report highlights the progress that has been achieved since the Inclusive Framework first met in Kyoto in June 2016. The meeting also approved the release of discussion drafts on Attribution of Profits to Permanent Establishments and Transactional Profit Splits.
The “Platform for Collaboration on Tax” published its final version of the toolkit designed to provide developing countries practical guidance on how to address the lack of comparables in transfer pricing. The toolkit includes a supplementary report on the pricing of transactions between related parties in the extractive industries and also addresses the information gaps on prices of minerals sold in an intermediate form (including concentrates).
Please click here to read more.
This article first appeared on transferpricing.co.za.