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Given that the base erosion and profit shifting schemes are often very complex, involving convoluted circumventions of complex tax provisions in various jurisdictions that are often shrouded in tax haven jurisdiction, it becomes difficult for revenue authorities to challenge their legality in a court. 102 United Nations Economic Commission for Africa, Base erosion and profit shifting in Africa: Reforms to facilitate improved taxation of multinational enterprises (Addis Ababa: Economic Commission for Africa, 2018), For South Africa to pursue such cases will require a large and long-term investments of skills and time

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