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  • Article

    Binding Private Ruling 156 (BPR 156): Pension Benefits Accruing To A Non-Resident From A Resident Pension Fund

    BPR 156 dealt with the question of whether a pension annuity and a retirement lump sum benefit will be taxable in South Africa, if it is received by or accrues to a person who is not a resident of South Africa, from a South African registered pension fund.
    South AfricaTax
    DLA Cliffe Dekker Hofmeyr
    DLA Cliffe Dekker Hofmeyr
  • Article

    Collateral Arrangements And Repos In Respect Of Equities And Bonds: A South African Tax Perspective

    Although the overall economics of repurchase arrangements ("repos") and collateral arrangements may be comparable in certain instances, the legal nature of these transactions...
    South AfricaTax
    ENS
    ENS
  • Article

    Debt Forgone For The Benefit Of Mining Companies

    The South African Taxation Laws Amendment Act, 2017 was signed into law on 18 December 2017 and made some notable changes to the tax regime.
    South AfricaTax
    ENS
    ENS
  • Article

    Dividends Tax: Most-Favoured Nation Clause In Double Tax Agreement

    On 12 June 2019, the Tax Court of South Africa delivered its judgment in ABC (Pty) Ltd v C:SARS (case no. 14287).
    South AfricaTax
    ENS
    ENS
  • Article

    South African Treatment Of Tax Debt | Webinar Series | Q&A

    If not considered to be carrying on a trade, could the foreign exchange gains and losses on foreign debt instruments be considered to be interest?
    South AfricaTax
    ENS
    ENS
  • Article

    Taxation Of Foreigners In South Africa

    It has always been a contentious issue as to the extent to which foreigners working in South Africa should be subject to tax in South Africa. In the absence of a double taxation agreement which governs the payment to the foreigners, one of the issues is whether remuneration is received by the foreigner in South Africa to the extent that it is actually paid by the South African employer to the foreigner.
    South AfricaTax
    ENS
    ENS
  • Article

    VAT Treatment Of Private Funding Received By Welfare Organizations

    The definition of "enterprise" in section 1 of the VAT Act includes the activities of the "welfare organization". The VAT Act defines the term "welfare organization" to mean any public...
    South AfricaTax
    SNG Grant Thornton
    SNG Grant Thornton
  • Article

    Voluntary Disclosure Programme : Deadline Looming

    We are heading into the last month for taxpayers to avail themselves of the VDP provided for in terms of the Voluntary Disclosure Programme and Taxation Laws Second Amendment Act ("the VDP Act").
    South AfricaTax
    ENS
    ENS
  • Article

    Want To Stay Abroad But Retain Employment From A South African Entity, What Are The Tax Implications For You And Your Employer?

    The tax season for individuals started in July 2022 and it will close in October. Many individuals who are tax residents in South Africa (RSA) may have been working abroad during the ...
    South AfricaTax
    SNG Grant Thornton
    SNG Grant Thornton
  • Article

    Expected Changes To Environmental Taxes

    In the National Budget Speech delivered on 20 February 2019, it was announced that National Treasury will publish a draft Environmental Fiscal Reform Policy Paper in 2019.
    South AfricaEnvironment
    Hogan Lovells
    Hogan Lovells
  • Article

    Changes to South Africa’s Retirement Fund Laws Coming Soon

    The Retirement Fund Reform Discussion Paper issued by the National Treasury in December 2004 elicited suggestions from a wide range of institutions and people. There were a number of excellent suggestions put forward and it is to be hoped that many of them will be incorporated into the draft Bill, which is now eagerly awaited.
    South AfricaStrategy
    Cliffe Dekker Hofmeyr
    Cliffe Dekker Hofmeyr
  • Article

    Amendments Relating To Dividend Exemptions In The Context Of Incentive Schemes

    Recent amendments were made to both the local dividend income tax exemption, as well the foreign dividend income tax exemption.
    South AfricaTax
    ENS
    ENS
  • Article

    Anti-Dividend Stripping Provisions

    Further details have just been released regarding the revised anti-dividend stripping tax avoidance provisions, which were announced by Finance Minister Tito Mboweni on 20 February 2019.
    South AfricaTax
    Bowmans
    Bowmans
  • Article

    Budget 2018 - Business Perspective

    The 2018 Budget Review contains a number of proposals that will impact businesses operating in South Africa.
    South AfricaTax
    Pieter van der Zwan & Associates
    Pieter van der Zwan & Associates
  • Article

    Capital Gains Tax Consequences Pursuant To A Bequest Releasing A Debtor From A Debt Owed To The Deceased

    Since the introduction of capital gains tax it has been a contentious issue whether capital gains tax would arise in circumstances where a testator releases a debtor from a debt owed by the debtor to the testator or where the testator would bequeath the subject matter of the debt to the debtor resulting in potential set-off or confusio.
    South AfricaTax
    ENS
    ENS
  • Article

    Changes To The Taxation Of Dividend Cessions And Manufactured Dividends

    In the 2013 Budget Review, which was released on 27 February 2013, specific mention was made that a research project is underway in which consideration is being given to a unified treatment of dividend cessions and manufactured dividends.
    South AfricaTax
    ENS
    ENS
  • Article

    Classification Of An Arrangement As An Interest-Bearing Instrument

    The Income Tax Act contains specific provisions relating to the timing of the accrual or incurral of interest for tax purposes. BPR272 deals with an arrangement that contains deferred payment...
    South AfricaTax
    Pieter van der Zwan & Associates
    Pieter van der Zwan & Associates
  • Article

    Coming To Grips With The New Sections 8E And 8EA

    In terms of the 2012 Draft Taxation Laws Amendment Bill, which was made available for comment on 13 March 2012, the long-awaited proposed amendments to sections 8E and 8EA of the Income Tax Act were published.
    South AfricaTax
    ENS
    ENS
  • Article

    Contingent Liabilities Assumed As Part Of A Going Concern

    The tax implications of assuming contingent liabilities as part of a sale of business present uncertainties for both sellers and purchasers.
    South AfricaTax
    Pieter van der Zwan & Associates
    Pieter van der Zwan & Associates
  • Article

    FATCA: Considerations For The South African Long-Term Insurance Industry

    The Foreign Accounts Tax Compliance Act had a very controversial reception by the global financial services community, and saw a robust lobbying effort against its more onerous obligations.
    South AfricaTax
    KPMG, South Africa
    KPMG, South Africa
  • Showing 101–120 of 711 results

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