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July/August 2018

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  • Sponsored by Nera
    The OECD BEPS initiative has introduced numerous likely challenges to transfer pricing structures defended through application of the transactional net margin method (TNMM). This article focuses on the economic analysis enhancements needed to make TNMM-type transfer pricing solutions sustainable in the future.
  • Sponsored by Webber Wentzel
    The use of real estate investment trusts (REITs) is becoming increasingly popular in South Africa. However, care needs to be taken where a South African REIT holds various foreign property owning subsidiaries either directly or through a non-South African intermediary holding company (IHC).
  • Sponsored by Garrigues Spain
    Subrogation to the tax rights and obligations in mergers, spinoffs and asset contributions, remains unaltered.