ArticleTax Residency - Place Of Effective Management In South AfricaThe concept of residency is a crucial determinant in establishing a person's tax obligations in South Africa.South AfricaTaxDentons
ArticleTaxation Laws Amendment Bills 2007Two Bills have recently been published in their final form, giving effect to the amendments announced in the Budget Speech last February. The most significant amendments relate to the decision to simplify the calculation of the taxable portion of lump sums from pension, provident and retirement annuity funds, and to reduce the tax burden on such sums. South AfricaTaxNorton Rose Fulbright South Africa
ArticleThe Tax Challenges Of International Remote WorkDue 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...South AfricaTaxENS
ArticleTrending In Tax — March 16, 2020Treasury excludes duty rebates for goods damaged, lost or stolen due to robbery and theft. Adjustments in the Employee Tax Incentive Act aim to boost youth employment and clarification on ...South AfricaTaxTabacks
ArticleMining Companies And Section 23KPrior to the introduction of section 23K by way of clause 49 of the Taxation Laws Amendment Bill, Bill 19 of 2011 (the "TLAB") whether or not a taxpayer was permitted a deduction in respect of interest expenditure, hinged upon whether or not the expenditure satisfied the requirements in terms of section 11(a), read together with section 23 of the Income Tax Act No. 58 of 1962 (the "Act"). South AfricaTaxENS
ArticleWhat Is Inside The New Rwanda Tax Procedure Law?Effective from 31 March 2023, Rwanda has a new law on tax procedures (see here) as part of tax reforms the country has embarked on in the last few years.South AfricaTaxENS
ArticleThe Legal And Operational Framework For Unbundling Transactions In Accordance With Section 46 Of The Income Tax ActSection 46 of the Income Tax Act 58 of 1962 (the "ITA") provides roll-over relief where a company distributes shares it holds in another company to its own shareholders...South AfricaCorporate/Commercial LawBarnard Inc.
ArticleCould Personal Income Tax Breaks Ensure That All Namibians Benefit From Petroleum Royalties?Estimates suggest that the Namibian Government could receive close to USD106-billion (NAD2-trillion at the time of writing) from its petroleum royalties alone...South AfricaEnergy and Natural ResourcesENS
ArticleThe Mauritian Global Business Sector RevampedThe legal framework in Mauritius is constantly evolving to keep pace with the rapidly changing economic environment. South AfricaFinance and BankingENS
ArticleApex Court Rules In Favour Of Coronation In Controlled Foreign Company DisputeThe Constitutional Court (CC) recently (21 June 2024) handed down judgment in the case of Coronation Investment Management SA (Pty) Ltd v CSARS (Coronation and SARS)...South AfricaTaxFasken
ArticleBudget 2012 – Tax ProposalsThe Minister of Finance Mr Pravin Gordhan delivered South Africa’s much anticipated 2012 Budget speech to Parliament this afternoon. South AfricaTaxBell Dewar
ArticleBudget Speech 2021: How The Tax Landscape Could ChangeSouth Africa's Minister of Finance, Tito Mboweni, is set to deliver the 2021 budget speech on 24 February.South AfricaTaxENS
ArticleOffshore Trusts: The Basic Considerations And Recent AmendmentsThe world of offshore trusts is now more dynamic than ever.South AfricaTaxENS
ArticleProposals To Encourage Retirement Savings Through Tax IncentivesFinance Minister Pravin Gordhan revealed a proposal to change legislation governing retirement fund contributions in the 2012 Budget. South AfricaTaxSNG Grant Thornton
ArticleSouth Africa National Treasury Warns Against Wealth Tax ProposalsWhile South Africa's government of national unity attempts to finalise the 2025 budget, a fierce debate has erupted over how best to raise revenue after it become clear...South AfricaTaxThe Sovereign Group
ArticleThe Concept Of Beneficial Ownership: Velcro Canada v The QueenThe concept of beneficial ownership has been prominent in double tax agreements ("DTA") based on the Organisation for Economic Co-operation and Development ("OECD") model treaties from as far back as 1977. South AfricaTaxENS
ArticleThe Effect of Transfer Pricing on Management FeesAsset management services performed by a resident in a different jurisdiction to the recipient of the services gives rise to potential transfer pricing implications that should be borne in mind. South AfricaTaxCliffe Dekker Hofmeyr
ArticleThe Global Minimum Tax Act – A Present And Pressing Reality For Multinationals Operating In South AfricaOn 20 December 2024 the President assented to the Global Minimum Tax Act (the Act) which applies from 1 January 2024, and enables South Africa to impose a top-up tax...South AfricaTaxFasken
ArticleThe Proposed Amendments To The International Headquarter Company RegimeA number of amendments are proposed in the Draft Taxation Laws Amendment Bill, 2012 (the "Draft TLAB") to section 9I of the Income Tax Act No. 58 of 1962 ("the Act") that deal with international headquarter companies ("the HQ Company"). South AfricaTaxENS