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  • Article

    Draft Legislation Proposes Significant Changes To The Tax Treatment Of Share Buy-Backs And Dividend Stripping

    In the 2016 annual Budget Speech the Minister of Finance indicated the possibility of legislative countermeasures to curb the use of share buy-back arrangements that resulted in no tax being triggered.
    South AfricaTax
    Fasken
    Fasken
  • Article

    Erosion And Profit Shifting (BEPS) – OECD Action Plan

    In February 2013, the Organisation for Economic Cooperation and Development published a report, Addressing Base Erosion and Profit Shifting, in which it stated the view represented by the OECD member countries on the matter.
    South AfricaTax
    KPMG, South Africa
    KPMG, South Africa
Article

Final Changes To The Special Voluntary Disclosure Programme

The SVDP legislation also deals with controlled foreign companies subject to the provisions of section 9D of the Income Tax Act.
South AfricaTax
ENS
ENS
  • Article

    Further Clarity On ‘Pay Now And Argue Later’

    In terms of the ‘pay now and argue later principle’ taxpayers are obliged to pay the South African Revenue Service any taxes due; albeit any pending court decisions or objections against any assessments.
    South AfricaTax
    Bell Dewar
    Bell Dewar
  • Article

    Impact Of The Recent ABSA Bank Limited And Another v CSARS Judgement

    South Africa's Tax Administration Act, 2011 ("the TAA") sets out the processes as to how a taxpayer may deal with an adverse South African Revenue Service ("SARS") assessment: the request for reasons, ...
    South AfricaTax
    Tabacks
    Tabacks
  • Article

    Impact Of The Recent ABSA Bank Limited And Another V CSARS Judgement On Taxpayers In The Tax Dispute Resolution Process

    It is possible to apply for suspension of this payment on specific application to SARS if the various motivating requirements/factors are met.
    South AfricaTax
    Tabacks
    Tabacks
  • Article

    Introduction Of Legislation To Implement Country-By-Country Reporting In South Africa

    Accordingly, it is possible that in drafting the CbC legislation, SARS and National Treasury will make reference to the Australian legislation to implement CbC reporting which was enacted in December 2015.
    South AfricaTax
    ENS
    ENS
  • Article

    Introduction Of Local Content-based Incentive To Promote Manufacturing

    Under tax incentives, the Minister proposed to introduce a local content allowance for income tax, relating to the use of selected local raw materials, at the rate of 2%.
    South AfricaTax
    Bowmans
    Bowmans
  • Article

    Landmark Judgement In Supreme Court Of Appeal Upholds Deferred Delivery Share Scheme

    In its first and much anticipated judgement in relation to the interpretation of section 8A of the Income Tax Act, and to Deferred Delivery Share Schemes, a full bench of the Supreme Court of Appeal unanimously upheld the taxpayers’ contentions.
    South AfricaTax
    ENS
    ENS
  • Article

    Law Imminent to Ensure Non-Residents Pay Capital Gains Tax

    An impending amendment to the revenue laws could cause a purchaser of immovable property to pay up to 10% of the purchase price by way of tax on behalf of a seller, plus penalties.
    South AfricaTax
    Cliffe Dekker Hofmeyr
    Cliffe Dekker Hofmeyr
  • Article

    Making Commercial Sense Of Section 24C

    The Commissioner for the South African Revenue Service recently published a Draft Interpretation Note on the allowance of future expenditure on contracts in terms of section 24C of the Income Tax Act 58 of 1962.
    South AfricaTax
    ENS
    ENS
  • Article

    Pay Now And Argue Later

    In terms of the ‘pay now and argue later principle’ taxpayers are obliged to pay the South African Revenue Service any taxes due; albeit any pending court decisions or objections against any assessments.
    South AfricaTax
    Bell Dewar
    Bell Dewar
  • Article

    Personal Income Tax Increases May Be On The Cards

    In his Medium-Term Budget Policy Statement, in October 2019, Finance Minister Mboweni warned that new tax measures may be announced.
    South AfricaTax
    Bowmans
    Bowmans
  • Article

    Proposed Unilateral Extension Of Prescription By SARS

    Due to the importance of prescription for taxpayers in obtaining finality as to their tax affairs, it is crucial for taxpayers to be aware of the prescription status of assessments and their rights in this context.
    South AfricaTax
    ENS
    ENS
  • Article

    Putting An End To The Abuse Of The Employment Tax Incentive ("ETI")

    Employment Tax Incentive ("ETI") programme was introduced in January 2014 to promote employment, particularly of young workers.
    South AfricaTax
    SNG Grant Thornton
    SNG Grant Thornton
  • Article

    Recent Case - Containers : What is a Normal Transaction?

    South AfricaTax
    Norton Rose Fulbright South Africa
    Norton Rose Fulbright South Africa
  • Article

    Recent Case On Judicial Review Of SARS’ Actions In Terms Of PAJA

    The South African Revenue Service ("SARS") increased their audit activity and focus on the collection of tax.
    South AfricaTax
    ENS
    ENS
  • Article

    Revenue Projections To Meet R35 Billion Additional Target – 2026

    It is becoming increasingly unlikely that SARS will meet the collection targets required to achieve the additional R35 billion reflected in National Treasury's monthly publications.
    South AfricaTax
    SNG Grant Thornton
    SNG Grant Thornton
  • Article

    SARS Issues Draft Interpretation Note On Intra-group Loans

    In February this year SARS published a Draft Interpretation Note on the determination of taxable income of certain persons from international transactions covering intra-group loans.
    South AfricaTax
    SNG Grant Thornton
    SNG Grant Thornton
  • Article

    Section 8E And 8EA - The Final Draft

    In the 2012 Taxation Laws Amendment Bill, the long-awaited proposed amendments to sections 8E and 8EA of the Income Tax Act, No 58 of 1962, were published.
    South AfricaTax
    ENS
    ENS
  • Showing 41–60 of 711 results

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