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BEPS was identified as a risk to tax revenues, tax sovereignty and the tax fairness of all countries by the OECD in 2013.

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...

The Supreme Court of Appeal delivered judgment in the case of Commissioner for the South African Revenue Service v Mobile Telephone Networks Holdings Ltd.

The Eighth Schedule to the Income Tax Act creates a tax liability known as capital gains tax which applies generally where an asset is disposed of.

Prior to the recent amendments in the Taxation Laws Amendment Act, a collective investment scheme was taxed on a semi-flow through regime.

Therefore, any amount referred to in section 8C that is required to be included in the income of a person constitutes "remuneration" for purposes of employees' tax.

It is no hidden secret that unemployment in South Africa remains considerably high.

A South African High Court has ruled on the lawfulness of account freezing by banks based on fraud suspicions and affirmed SARS's authority to issue third-party notices under section 179 of the Tax Administration Act. The case arose after a close corporation fraudulently claimed a VAT refund of R3.28 million, transferred R900,000 to an individual's account, prompting the bank to freeze the account and SARS to pursue recovery through a third-party notice.

Last year, the Organisation for Economic Co-operation and Development, a highly influential global body that directs economic policy among the world’s wealthiest nations, announced an initiative to combat so-called co-called Base Erosion and Profit Shifting.

The Taxation Laws Amendment Act of 2015 ("Amendment Act") was promulgated on 8 January 2016 and contains a number of legislative changes to the Income Tax Act, 58 of 1962 ("the Act").

The provisions of section 20 of the Act provides that taxpayers can set off their balance of assessed losses carried forward from the preceding tax year against their income in determining taxable income.

The Tax Court has ruled on whether a taxpayer may amend its appeal statement to introduce new factual grounds supporting a disputed VAT input tax deduction, years after the original objection was filed. The decision clarifies the boundaries of Rule 32(3) of the Tax Court Rules and examines when late amendments will be permitted despite weak explanations for delay.

It is proposed in the draft Taxation Laws Amendment Bill, released for comment on 4 July, that hedge funds should be included in the tax regime for collective investment schemes.

The process to be followed by taxpayers when disputing assessments issued by the South African Revenue Service ("SARS") is set out in the Tax Administration Act, 2011 (the "TAA") read with the rules promulgated under section 103 of the TAA.

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.

Budget Speech time is rapidly approaching and taxpayers will be looking to the Minister of Finance for details on how he plans to fill the government coffers for the 2013 fiscal year.

National Treasury published a draft amendment to the Domestic Reverse Charge ("DRC") Regulations on Valuable Metal on 1 August 2024, which will result in many (gold) mining title holders to be subject to the value-added tax ("VAT") reverse charge with effect from 1 April 2025.