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  • Article

    Status Of Transfer Pricing In Africa (Part I)

    A number of regional and international developments have contributed to the current emphasis on transfer pricing by African tax authorities.
    South AfricaTax
    ENS
    ENS
  • Article

    Tax Consequences Of Foreign Companies Rendering Services In South Africa

    In the case of X LLC, case number 13276 heard in February 2015, as yet unreported, the Tax Court had to determine whether X had created a permanent establishment in South Africa, and was liable to tax in South Africa.
    South AfricaTax
    ENS
    ENS
  • Article

The Concept Of Beneficial Ownership: Velcro Canada v The Queen

The 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 AfricaTax
ENS
ENS
  • Article

    The Effect of Transfer Pricing on Management Fees

    Asset 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 AfricaTax
    Cliffe Dekker Hofmeyr
    Cliffe Dekker Hofmeyr
  • Article

    The Global Minimum Tax Act – A Present And Pressing Reality For Multinationals Operating In South Africa

    On 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 AfricaTax
    Fasken
    Fasken
  • Article

    The Proposed Amendments To The International Headquarter Company Regime

    A 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 AfricaTax
    ENS
    ENS
  • Article

    The Supreme Court Of Appeal Weighs In On The Meaning Of "Bona Fide Inadvertent Error"

    Tax law is often difficult to interpret and frequently the South African Revenue Service ("SARS") and the Courts hold a different view to that of a taxpayer and its advisers.
    South AfricaTax
    ENS
    ENS
  • Article

    The VAT Advantage: Smart Tax Moves For Vendors In The Food And Beverage Industry

    For enterprises in South Africa that operate within the dynamic food and beverage industry, understanding and effectively utilising indirect tax incentives are a powerful way to enhance profitability and gain a competitive edge.
    South AfricaTax
    Webber Wentzel
    Webber Wentzel
  • Article

    Think Green, Think Tax: Mauritius' Corporate Climate Responsibility Levy

    The introduction of a Corporate Climate Responsibility Levy (the "CCR Levy") was announced as part of the Mauritius National Budget 2024/2025.
    South AfricaTax
    ENS
    ENS
  • Article

    Which Taxes Apply To Share Loans?

    The ability to enter into loans over listed shares is an important part of the financial industry as it offers sellers of listed shares the ability to comply with their obligations to deliver shares under a short sale contract.
    South AfricaTax
    ENS
    ENS
  • Article

    Externalising IP?- What Do You Need To Know

    Despite challenges faced in recent years with the global pandemic as well as political and economic instability, South Africa has a booming fintech and technology industry.
    South AfricaCorporate/Commercial Law
    ENS
    ENS
  • Article

    Practical Challenges And Legal Complexities – Does SARS Owe You A Mineral Royalty Refund?

    Promulgated in November 2009, the Mineral and Petroleum Resources Royalty Act No. 28 of 2008 (‘Royalty Act') has been in effect for almost 14 years.
    South AfricaEnergy and Natural Resources
    ENS
    ENS
  • Article

    A Valid Will Is Not Always Enough

    Estate planning extends far beyond drafting a valid Will. This article examines the critical but often overlooked issue of estate liquidity—the availability of cash to settle taxes, debts, and administration costs—and explains why asset-rich estates can still face serious financial challenges during administration.
    South AfricaFamily and Matrimonial
    Fairbridges
    Fairbridges
  • Article

    Another Ruling On Income Tax Allowances For Future Expenditure

    Under section 24C of the Income Tax Act 58 of 1962, if a taxpayer receives income under a contract in a tax year.
    South AfricaCorporate/Commercial Law
    Cliffe Dekker Hofmeyr
    Cliffe Dekker Hofmeyr
  • Article

    New Cases: Is a Forex Dealer Trading Inside or Outside South Africa?

    The mass of recent tax legislation and the increasing complexity of business have meant that not many tax cases reported in the past few years have involved a simple enquiry to be dealt with by means of old established precedent from the courts. The recently reported <B><U>ITC 1779 66 SATC 353</B></U> is, however, such a case.
    South AfricaCorporate/Commercial Law
    Norton Rose Fulbright South Africa
    Norton Rose Fulbright South Africa
  • Article

    Dividend Payment Cycles In Turbulent Times

    The negative economic impact of the global COVID-19 pandemic has been widespread and has led to a number of adverse outcomes.
    South AfricaFinance and Banking
    ENS
    ENS
  • Article

    Africa Regulatory ENSight

    Approves a new regime on the entry, exit, and staying of foreign citizens in Angola; and
    South AfricaGovernment, Public Sector
    ENS
    ENS
  • Article

    Intellectual Property Holding Companies And R&D Tax Credits

    As intellectual property rights become increasingly important business assets, the need for tax planning in relation to IP becomes more important.
    South AfricaIntellectual Property
    ENS
    ENS
  • Article

    Africa Tax In Brief - 27 Apr 2016

    The amending protocol to the Botswana/Sweden Income Tax Treaty (1992), which was signed on 20 February 2013, entered into force on 1 December 2015.
    South AfricaTax
    ENS
    ENS
  • Article

    Application Of Liquidation Rollover Provisions To A Transfer Of Business

    An interesting issue arises whether the provisions of section 47 of the Income Tax Act ("Act") may be used in circumstances where a company transfers a business including liabilities to its parent company.
    South AfricaTax
    ENS
    ENS
  • Showing 641–660 of 1252 results

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