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  • Article

    Related Party Loans And The Arm's Length Principle

    Thin capitalisation rules are specific anti-avoidance provisions, very closely related to transfer pricing as they are designed to combat the extraction of profits from South Africa.
    South AfricaTax
    Routledge Modise
    Routledge Modise
  • Article

    Reorganisation Transactions And The Deduction Of Interest In Terms Of The New Section 23K

    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.
    South AfricaTax
    ENS
    ENS
Article

Share Conversions – Clarity On The Income Tax Consequences

With the introduction of the new Companies Act, a number of implications arise in relation to the interpretation and application of the Income Tax Act.
South AfricaTax
ENS
ENS
  • Article

    The South African Taxation Of Trusts: Recent Developments

    The Davis Tax Committee's first interim report was released in July 2015 and made various significant recommendations to the Minister of Finance regarding the taxation of trusts in South Africa.
    South AfricaTax
    ENS
    ENS
  • Article

    The Voluntary Disclosure Programme And Tax Defaults Post 17 February 2010 (Recent Developments in Corporate Taxation, May 2011)

    Much has been written about the Voluntary Disclosure Programme (VDP) which aims to get taxpayers to regularise their tax affairs in a manner that will encourage them to come forward with the knowledge that, although the tax amounts remain due, they will (in most cases) be absolved from paying any penalties and interest, with no criminal action being taken against them.
    South AfricaTax
    Werksmans Attorneys
    Werksmans Attorneys
  • Article

    Companies, tax acts mismatch

    The new Companies Act introduces changes to existing company law principles. However, what is not widely understood is the effect these changes will have on existing income tax principles.
    South AfricaCorporate/Commercial Law
    ENS
    ENS
  • Article

    Debt Waivers: Reduction/Cancellation Of Debt

    The Taxation Laws Amendment Act, 2012, has amended the tax consequences of debt reduction transactions entered on or after 1 January 2013.
    South AfricaTax
    KPMG, South Africa
    KPMG, South Africa
  • Article

    Investing In And Divesting Of South African Mining Assets

    It is common knowledge that investing in a South African prospecting or mining company is a long term, capital intensive and risky investment. It is common knowledge that investing in a South African prospecting or mining company is a long term, capital intensive and risky investment. Potential investors seek not only security over the assets but also an attractive return on investment.
    South AfricaTax
    ENS
    ENS
  • Article

    Budget Promises Don’t Always Translate Into Reality

    Promises of job creation, fighting poverty, unemployment and government improving its service delivery mechanisms took centre stage in the Finance Minister’s Budget speech.
    South AfricaTax
    KPMG, South Africa
    KPMG, South Africa
  • Article

    Recent Case Law Regarding The Employees’ Tax Implications Of A Company Car Scheme In The Spotlight

    The South African Revenue Service ("SARS") assessed the taxpayer for employees' tax for the period 1 March 2003 to 29 February 2008 in terms of the provisions of the Fourth Schedule to the Income Tax Act No. 58 of 1962 ("Act").
    South AfricaTax
    ENS
    ENS
  • Article

    Share Disposals Deemed To Be Of A Capital Nature – Implications For Share Dealers (Draft Interpretation Note 43, Issue 3) - Recent Developments in Corporate Taxation (May 2011)

    On 28 March 2011 SARS issued a draft interpretation note (DIN) regarding the application of section 9C of the Act, the so called "safe haven" provision on shares.
    South AfricaTax
    Werksmans Attorneys
    Werksmans Attorneys
  • Article

    The Anti-Global Base Erosion Rules Released: What It Means For MNE Taxation

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

    The Headquarter Tax Regime

    The definition of headquarter company was introduced as section 9I of the Income Tax Act No. 58 of 1962 with effect from the commencement of years of assessment commencing on or after 1 January 2011.
    South AfricaTax
    ENS
    ENS
  • Article

    No Tax Relief For Hedge Funds?

    With effect from 1 April 2015, the business of a hedge fund has been declared to be a collective investment scheme ("CIS") in terms of section 63 of the Collective Investment Schemes Control Act 45 of 2000 ("CISCA").
    South AfricaTax
    ENS
    ENS
  • Article

    Reorganisation Transactions And The Impact Of Section 23K

    The Taxation Laws Amendment Bill, Bill 19 of 2011 introduced to Parliament on 25 October 2011, contains the proposals of the South African Revenue Service ("SARS") and the National Treasury relating to debt-funded reorganisation transactions as contained in their joint press release of 3 August 2011.
    South AfricaTax
    ENS
    ENS
  • Article

    The Implementation Of A Full Group Taxation System In South Africa

    Over the last several years, the government has taken significant steps to improve the competitiveness of the tax system for South African businesses.
    South AfricaTax
    ENS
    ENS
  • Article

    Africa Tax In Brief - October 2014

    Angola's tax reform included the adoption of three new laws and a reduction in the corporate income tax rate from 35 to 30 percent.
    South AfricaTax
    ENS
    ENS
  • Article

    Cash Versus In Specie Dividends

    With the introduction of the new dividends tax on 1 April 2012, the distinction between cash dividends and dividends in specie requires consideration.
    South AfricaTax
    ENS
    ENS
  • Article

    Increase In East Africa 2015/16 Budgets

    East African governments have increased their annual budgets for 2015/16 with more spending directed towards security and key sectors expected to drive growth.
    South AfricaTax
    ENS
    ENS
  • Article

    Limiting Interest Deductions

    In the 2013 Budget Speech, the Minister of Finance announced that restricting the deduction of excessive interest expenditure claimed by taxpayers in debt financing schemes has been on the tax policy agenda for a number of years and accordingly, legislative steps are now being taken to limit the interest deductions claimed by taxpayers in such schemes.
    South AfricaTax
    ENS
    ENS
  • Showing 61–80 of 213 results

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