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

The United Kingdom / Zambia Income and Capital Tax Treaty (2014) entered into force on 20 July 2015 and will generally apply from 1 January 2016.

In terms of section 64E(1)(a) of the Income Tax Act 58 of 1962 ("the ITA") dividends tax at a rate of 20% must be paid when a South African company declares and pays a dividend.

On 31 May 2022, the OECD published its Fifth Peer Review Report on Treaty Shopping. The report includes extensive information on tax treaties concluded by the countries...

Parties entering into cross-border transactions must consider the possibility of the transaction giving rise to a permanent establishment for either party, with an eye to avoiding this problem where possible.

In the case Attorney-General of Canada v RJ Reynolds Tobacco Holdings Inc and Others heard in the US Supreme Court of Appeals for Second Circuit, 12 October 2001, 268 F 3d 103, the ‘revenue-rule’ principle was confirmed.

Following the drastic 18-month suspension of the intra-group relief available in section 45 of the Income Tax Act 58 of 1962 ("the Act") announced on 2 June 2011 in the Draft Taxations Laws Amendment Bill, 2011.

A protocol amending the double tax agreement (DTA) between South Africa and Sweden took effect from 18 March 2012.

The hiatus of section of 45 of the Income Tax Act, No. 58 of 1962 (the Act) with effect from 3 June 2011 has been highlighted quite significantly in the press.

South Africa has entered into a number of Agreements for the Prevention of Double Taxation ("DTA’s") with other states which contain an exchange of information clause.

South Africa has entered into a number of Agreements for the Prevention of Double Taxation ("DTA’s") with other states which contain an exchange of information clause.

With effect from 1 March 2015, withholding tax on interest will be levied at a rate of 15% in respect of interest that is paid by any person to or for the benefit of any foreign person.

National Treasury has proposed the introduction of new rules for the tax treatment of conversions of debt into equity within the same group of companies.

In an increasingly globalised economy, many South Africans are exploring offshore investments as a way to diversify their portfolios and mitigate local economic risks

The long-awaited double tax agreements entered into by Kenya with South Africa and Mauritius respectively did not come into force on 1 January 2015 as expected.

On 20 December 2021, the Anti-Global Base Erosion ("GloBE") Rules were released by the OECD.

Judgment was delivered by Acting Judge of Appeal, Boruchowitz AJA in the Supreme Court of Appeal ("SCA") ((132/11) [2012] ZASCA 61) between the Commissioner for the South African Revenue Service ("Commissioner") and Tradehold Limited ("Tradehold") on 8 May 2012.

The Tax Administration Bill, 2011, (TAB) which is expected to be enacted later this year contains a permanent Voluntary Disclosure Programme (TAB VDP) which provides relief to non-compliant taxpayers, albeit on less favourable terms than the current VDP under the Voluntary Disclosure Programme and Taxation Laws Second Amendment Act No. 8 of 2010.

With the recent announcement of the intention to introduce a uniform tax withholding rate of 15% for dividends, interest and royalties, the reduction of these taxes by foreign investors into South Africa will be an increasingly prominent feature in planning inward investment.

Due to the impact of the COVID-19 pandemic, many employers have seen an increased demand for international remote working arrangements. We have briefly touched upon...