Tax Intelligence book
I wrote a book on tax risk management that includes tax and strategy.
It is called TAX INTELLIGENCE and is available on Amazon.
However, I am willing to send free pdf copies to those who request it – please send your requests to daniel@TaxRiskManagement.com. I will also send you a summary version. The book has been used in college tax classes on tax risk management and strategy.
Letter of findings judgment ITC 13726
- Malawi – information unlawfully obtained to effect a TP adjustment;
- Malawi – VAT and “imported services” – “money” or its value is excluded from the VAT Act. Also, the neutrality principle applies;
- Zimbabwe – s98 general anti-avoidance provision applied to “impute” royalties and management fees in a TP adjustment contrary to longstanding general anti-avoidance principles – King’s case, G-Bank case and Brummeria referred to, with Silke as authority that an “amount” must exist before the general provisions are applied;
- Malawi – Article 9 is used to charge tax based on a TP adjustment – Australia Chevron case and Prof B Arnold referred to; TP law applied retrospectively; TNMM study converted to Cost plus method;
- Zambia – TP audit evidence ignored as product supply recategorized as intra-group services;
- Tanzania – PE issue where offshore Holdco deemed to conduct a PE in its Tanzanian Subco, and no allocation of income/profits;
- Mauritius – s19 interest deduction disallowed where a company made loans to its Subcos to facilitate earning income from its services – Drakensberg Gardens case;
- RSA – TP adjustment distorting the PSM method.