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  • Article

    Section 42 Asset-For-Share Transactions: The Unsuspected Dangers When Transferring Immovable Property

    Section 42 of the Income Tax Act, Act 58 of 1962 (herein the "ITA"), allows for the tax implications, normally associated with a disposal of assets...
    South AfricaTax
    Barnard Inc.
    Barnard Inc.
  • Article

    Share Loans And Repos: A South African Tax Perspective

    Although the overall economics of share lending arrangements ("share loans") and repurchase arrangements ("repos") may be comparable in certain instances...
    South AfricaTax
    ENS
    ENS
  • Article

    Proposed Change To The Tax Treatment Of Trust Income Vested In Non-resident Beneficiaries

    A significant change to the tax treatment of income which is vested by a South African trust in non-resident beneficiaries has been proposed in Annexure C of the 2023 Budget Review...
    South AfricaTax
    ENS
    ENS
  • Article

    The Limits Of New Grounds Of Appeal

    Rule 32(3) of the Rules promulgated under section 103 of the Tax Administration Act 28 of 2011 ("Tax Court Rules"), as amended...
    South AfricaTax
    ENS
    ENS
  • Article

    Capital Gains Tax And The Primary Residence Exemption

    A discussion on the restrictions to the capital gains exemption which normally applies to individuals selling their home.
    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

    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

    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

    Founder Shares: Do The Tax Rules Follow The Commercial Reality?

    Founders of businesses will usually inject large amounts of intellectual capital into their ventures apart from economic capital from banks and seed capital from investment pundits.
    South AfricaTax
    Bowmans
    Bowmans
  • Article

    New Treatment Introduced For Trust Distributions To Non-Tax Residents

    The South African Income Tax Act was amended to align the tax treatment of income distributions from trusts to non-resident beneficiaries with the tax treatment of capital distributions...
    South AfricaTax
    The Sovereign Group
    The Sovereign Group
  • Article

    Tax-Deferred Growth Through Corporate Rollovers

    This article forms part of a series of articles exploring the corporate reorganisation rules under the South African Income Tax Act 58 of 1962 (the "ITA"). Each entry in this series will discuss...
    South AfricaCorporate/Commercial Law
    Barnard Inc.
    Barnard Inc.
  • Article

    Why South African Entrepreneurs Should Consider Setting Up Offshore To Attract Foreign Investment

    South Africa boasts the most advanced, broad-based economy in sub-Saharan Africa, which offers a wide range of opportunities to South African business owners and foreign investors alike.
    South AfricaGovernment, Public Sector
    The Sovereign Group
    The Sovereign Group
  • Article

    Exit Charge: SARS Takes Its Own

    The first draft of the Taxation Laws Amendment Bill, 2013 was published by National Treasury on 4 July 2013.
    South AfricaTax
    ENS
    ENS
  • Article

    Tax In Brief | Issue 65

    Below, please find issue 65 of ENSafrica's tax in brief, a snapshot of the latest tax developments in South Africa.
    South AfricaTax
    ENS
    ENS
  • Article

    Important Change To Participation Exemption In Respect Of Sale Of Shares In A Foreign Company

    South African residents are taxed on their worldwide income, and a capital gain arising from the sale of shares in a foreign company will be subject to South African tax unless an exemption applies or a double tax agreement provides otherwise
    South AfricaTax
    ENS
    ENS
  • Article

    Issue Of Shares As Consideration

    In order for the ownership of assets to pass from a seller to a buyer it is necessary that the parties agree three essential elements: price, terms and structure. In order for the ownership of assets to pass from a seller to a buyer it is necessary that the parties agree three essential elements: price, terms and structure.
    South AfricaTax
    ENS
    ENS
  • Article

    The 2019 Budget And Proposed Tax Changes

    Taxpayers have been identified as abusing the newly introduced amendments in 2018.
    South AfricaTax
    Hogan Lovells
    Hogan Lovells
  • Article

    Bad Debts: Effect On Exchange Gains Or Losses

    The tax treatment of unrealised exchange gains or losses poses certain challenging questions when a foreign denominated debt becomes irrecoverable.
    South AfricaInsolvency/Bankruptcy/Re-Structuring
    Pieter van der Zwan & Associates
    Pieter van der Zwan & Associates
  • Article

    Avoid Future Headaches: Raising All Grounds Of Objection Is Critical In SARS Tax Disputes

    In recent years, SARS' has become increasingly litigious, resulting in disputes often ending up in the Tax Court or the High Court. Such a dispute will generally arise when a taxpayer...
    South AfricaTax
    ENS
    ENS
  • Article

    Capital Gains Tax: Cancellation Of Disposals

    Capital gains tax is imposed on any amount that a taxpayer becomes entitled to as a result of a disposal of an asset, whether this amount has been received in cash or not.
    South AfricaTax
    Pieter van der Zwan & Associates
    Pieter van der Zwan & Associates

Showing 21–40 of 179 results

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