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Africa: Various tax related updates

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New Developments

Nigeria: February 2015 Tax Calendar

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PwC Nigeria

In this time of falling government revenue, there is a lot of focus on tax compliance by various tax authorities.

Nigeria: FIRS Retains Interest Rate For Tax Default At 15{780f53c297e2c008074d23b865a0ce0b35a4f08852d8e1e49466a5a902c4e44e} For 2015

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PwC Nigeria

The law establishing the FIRS, the Federal Inland Revenue Service (Establishment) Act, prescribes interest rate for late or non payment of tax at CBN Monetary Policy Rate (MPR) plus a spread (additional rate) to be announced by the Finance Minister.

Nigeria: Non Resident Companies To File Full Tax Returns Effective From 2015 Tax Year

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PwC Nigeria

The FIRS has issued a Public Notice informing all taxpayers, especially non resident companies carrying on business in Nigeria, to submit full income tax returns as required by law.

Nigeria: What Price Should An Oil Company Use To Determine Its Revenue For Tax Purposes?

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PwC Nigeria

Generally the FIRS would seek to use the higher of the OSP and the RP for tax assessments.

South Africa: Effect Of Taking Professional Advice On Imposition Of Understatement Penalties And Interest

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ENSafrica

The court came to the conclusion that the taxpayer’s reliance on the advice received was reasonable and therefore directed that the Commissioner should waive the section 89quat interest in full.

South Africa: When Interest Becomes A Dividend: Hybrid Debt Instruments

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Cox Yeats

As of 1 April 2014 the Income Tax Act 58 of 1962 (the Act) was amended to regulate “hybrid debt instruments” more closely.

Mozambique: Mozambique’s Decree Law: Worth The Wait

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Shearman & Sterling LLP

The much anticipated Decree Law for Offshore Areas 1 and 4 was published on 2 December 2014 (Decree Law No. 2/2014).

Zambia: Zambia Mining Tax Amendments

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ENSafrica

These changes will not apply to the mining of industrial minerals such as lime, sand and gravel.
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Choose the track that fits your practice focus. All programmes are practitioner-taught, cohort-based, and validated by Middlesex University.

Dimension Transfer Pricing International Taxation South African Tax Law
Jurisdictional audience Global audience, covers all jurisdictions Global audience, covers all jurisdictions South Africa specific, relevant to SADC region
Ideal for TP managers, advisors, in-house tax teams, analysts moving into TP Advisors and managers dealing with cross-border rules, treaties, planning Practitioners working with the SA Income Tax Act, cases, compliance
Core focus Methods, comparables, DEMPE, documentation, audits, dispute defence Treaties, source vs residence, anti-avoidance, PE, relief from double tax Statutory interpretation, case law, assessments, objections, local practice
Primary tools OECD TP Guidelines, UN Manual, BEPS Actions 8–10, 13, case law OECD and UN Models, MLI, BEPS 1.0 and 2.0, domestic rules, cases Income Tax Act, SARS practice notes, Tax Administration Act, SA cases
Assessment style Case-based assignments, file reviews, short written defences Problem questions, treaty interpretation, position papers Problem questions, statutory analysis, case commentary
Typical outcomes Build defensible TP files and strategies, improve audit readiness Design cross-border structures within rules, mitigate double tax Apply SA tax law accurately, manage reviews and disputes
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PG Certificate Foundation to intermediate upskilling Core concepts, frameworks, and applied techniques Short case write ups, timed responses, applied tasks
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Practical, practitioner-led certificates designed for immediate on-the-job application. Each course can stand alone or act as a pathway into our postgraduate tracks.

Dimension Conducting a Transfer Pricing Trial Effectively Managing Tax Teams Indirect Taxation Tax Risk Management
Jurisdictional audience Global audience Global audience Global audience, with local adaptation Global audience
Ideal for In-house tax, TP managers, litigators, advisors preparing for audits, ADR, trial Heads of tax, managers, team leads, controllers, emerging leaders VAT, GST, customs, finance managers, AP, AR, compliance specialists Tax managers, risk officers, controllers, advisors building governance
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Assessment End of module progress assessment

5000-word assignment if PG-Cert option elected		 End of module progress assessment

5000-word assignment if PG-Cert option elected		 End of module progress assessment

5000-word assignment if PG-Cert option elected		 End of module progress assessment

5000-word assignment if PG-Cert option elected