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Results: 1-10 of 12

National broadband policy consultation document published for comment

  • DLA Cliffe Dekker Hofmeyr
  • -
  • Australia
  • -
  • April 19 2013

The Minister of Communications, on 3 April 2013, published a proposed National Broadband Policy for South Africa. Comments on or before 16 May 2013

Understatement penalty: when can SARS potentially allege 'gross negligence' or 'intentional tax evasion'?

  • DLA Cliffe Dekker Hofmeyr
  • -
  • Australia, South Africa
  • -
  • April 19 2013

The Tax Administration Act, No 28 of 2011 (TAA) introduces the 'understatement penalty' in Chapter 16. Section 223 contains an 'understatement

Third party appointments an Australian cat amongst the pigeons??

  • DLA Cliffe Dekker Hofmeyr
  • -
  • Australia, South Africa
  • -
  • January 21 2013

A recent Tax Alert (16 November 2012) considered SARS's ability to make third party appointments under s179 of the Tax Administration Act, No 28 of

Australian GAAR to be amended retrospectively lessons from down under

  • DLA Cliffe Dekker Hofmeyr
  • -
  • Australia, South Africa
  • -
  • August 3 2012

The Australian General Anti-Avoidance Rule (GAAR) is found in Part IVA of the Income Tax Assessment Act, 1936

Sent packing

  • DLA Cliffe Dekker Hofmeyr
  • -
  • Australia, South Africa
  • -
  • May 18 2012

Mr Eduard Sent (Sent) was sent packing by the Federal Court of Australia (FCA) on 16 April 2012, in an appeal against a decision by the Administrative Appeals Tribunal (Tribunal) on whether some or all of a payment of $11,600,000 to an executive share trust (Trust) was assessable as income in the hands of Sent (Sent v Commissioner of Taxation 2012 FCA 382

Australia introduces carbon-pricing mechanism

  • DLA Cliffe Dekker Hofmeyr
  • -
  • Australia
  • -
  • August 12 2011

In December 2010, National Treasury released a discussion paper on the introduction of a carbon-pricing mechanism in South Africa

Transfer pricing

  • DLA Cliffe Dekker Hofmeyr
  • -
  • Australia
  • -
  • June 17 2011

Transfer pricing cases are reading for lawyers with stamina

The IBM case - whether all payments made in terms of a software licence agreement constitute royalties for purposes of a treaty

  • DLA Cliffe Dekker Hofmeyr
  • -
  • Australia
  • -
  • May 6 2011

The Federal Court of Australia on 12 April 2011 gave a far-reaching judgment in the case of International Business Machines Corporation (IBM) v COT dealing with the question whether all payments made by IBM to its US holding company constituted royalties for purposes of the Treaty concluded between Australia and the USA

Australian perspective on privileged tax advice provided by accountants

  • DLA Cliffe Dekker Hofmeyr
  • -
  • Australia, South Africa
  • -
  • April 21 2011

Having regard to the complex tax and accounting rules and the interaction between these two disciplines across the globe, the logical conclusion is that tax is no longer the sole playground of lawyers

Carbon taxes

  • DLA Cliffe Dekker Hofmeyr
  • -
  • Australia, South Africa
  • -
  • April 8 2011

We have been following the space on the proposed Carbon Tax carefully