The study analyzes the effectiveness and normative coherence of the four De #Minimis exclusions in the #EU's Anti-Tax Avoidance Directive (#ATAD) controlled foreign company (#CFC) rules, concluding that while Model A exclusions have limited effectiveness, Model B exclusions lack justification and should be removed. Monique Malan wrote the article for the journal Intertax, including an introduction, the CFC legislation in the EU, the purpose of De Minimis exclusions in CFC legislation, evaluating the De Minimis exclusions, and ending with a conclusion. The article is published on kluwerlawonline.com
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Advocate General Medina: ECJ should annul European Commission decision that UK granted illegal State aid (tax rulings issued to certain MNE groups)... "Both the Commission and the General Court erred in law when considering the [CFC] rules, instead of the general UK corporation tax system, were the correct reference framework for examining whether a selective advantage had been granted." #internationaltax #EU #StateAid #UK #CFC #ECJ #CJEU
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[Tax publication] SARS has experienced several cases of eFiling profile hijacking of late. What measures have been put in place to avoid more cases in future? Yolisa Dyasi of SAIT expands on this in Issue 107 of the TaxTalk magazine. Click here to access the publication https://ow.ly/Sqhz50PET8z #SAIT #tax #SARS #filingseason #efiling #digitalfraud
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eFiling profile hijacking has unfortunately been on the rise. Here are some proactive measures you can take to protect your profile and client information #sars #sait #tax #efiling
[Tax Practitioner Alert] There have been several incidences of eFiling profile hijackings reported to SARS and SAIT over the past 2 months. Whilst these cases are reacted to with utmost urgency, the proactive safeguarding of eFiling profiles is still of paramount importance. Based on thorough investigations, SARS has published some tips on how to proactively keep your eFiling profile and client information safe. See document below. #sait #sars #tax #efiling
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The Central Board of Direct Taxes (CBDT) has established an internal committee to supervise an extensive review of the Income-tax Act, 1961 (Act). In order to decrease disagreements and litigation and give taxpayers more tax certainty, the Act is intended to be brief, understandable, and unambiguous. According to a Press Information Bureau (PIB) release on 7th Oct 2024, the committee invites public inputs and suggestions in four categories: Simplification of Language Litigation Reduction Compliance Reduction, and Redundant/Obsolete Provisions To facilitate this, a webpage has been launched on the e-filing portal with the link given in comments section below. The public can access the page by entering their mobile number and validating it via OTP. Take avail of this opportunity by voicing your opinion. #CBDT #Incometaxact1961 #charteredaccountant #taxation #taxlaws
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Numerous countries have now either adopted some form of EOT model, Canada being one of the more recent countries. Pete and I wrote a piece in the Canadian Publication "Perspectives on Tax Law and Policy" about the UK EOT regime. For anyone interest in wider EOT policy and how the UK regime compares to the Canadian, the publication can be found here: https://ow.ly/HqY950TlGXU #EOTModel #TaxLaw #Policy #EmployeeOwnership
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CBDT Authorizes Income-Tax Authorities to Admit Claims for Refunds and Loss Carry Forward Read more: https://lnkd.in/eE2AtgR5 CBDT #IncomeTax #Refunds #CarryForwardLosses #Section119 #TaxRelief #TaxCompliance #IndiaTax #IncomeTaxAct #TaxUpdates
CBDT Authorizes Income-Tax Authorities to Admit Claims for Refunds and Loss Carry Forward - Aaerm Law Associates
https://aaermlawassociates.com
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GSTN releases detailed Frequently Asked Questions (FAQs) on GSTR-1A – Amendment to GSTR-1; This advisory might come in handy while accessing GSTR- 1A ‘optional’ facility to add, amend or rectify any particulars of a supply reported/missed in the current tax period’s GSTR-1 before filing of GSTR-3B with introduction of Form GSTR-1A
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In a significant ruling for Multi-National Enterprises (MNEs) on Transfer Pricing, the Tax Court favoured ABD Limited in a case against South African Revenue Service (SARS), emphasising the importance of adhering to the "arm's length principle" and the intricacies of Transfer Pricing laws. This principle, crucial for international tax and compliance, requires transactions between related companies to be conducted as if they were between unrelated parties. The case highlighted the challenges MNEs face, such as ensuring accurate tax and legal foundations for transactions, especially in the software and technological advancement industry where licensing intellectual property is common. The judgement sends a strong message that SARS, under Commissioner Kieswetter, will not tolerate non-compliance, aligning with a global crackdown on tax avoidance. Read more here: https://bit.ly/4cbGWbc #SARS #TaxCompliance #Tax #Kieswetter #MNEs
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SECTION 153C: LIMITATION, COMPUTATION AND SATISFACTION Whether the period of limitation for the purpose of Section 153C read with 4th proviso to section 153A is required to be computed from the year of handover of search material to assessing officer of non-searched person or from the year of search in case of searched person? #LegalUpdate #Tax #Vaish #LegalNews #Taxbuzz #TaxUpdate
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We urge HM Revenue & Customs to improve its capital allowances guidance, focusing on updates for recent case law, tax code changes and tech developments. See our initial feedback: https://ow.ly/4GTX50TRPiu #icaewDaily #taxnews
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