*Coronavirus (COVID-19) regulatory measures...

In general, non-resident licensors are only subject to tax in South Africa on income that is attributable to a permanent establishment in South Africa of that licensor; or to the extent that tax is

In 2019, the Tax Court in ABC Proprietary Limited v C: SARS (Case No. 14287) 82 SATC 144 held that the most favoured nation ("MFN") article which is contained...

According to the announcement issued by the Rwanda Revenue Authority ("RRA") on December 13, 2019, the applications for quitus fiscal in relation to the fiscal year 2020 are open from today (December 16, 2019).

Over the last two days, Uganda and Kenya have both announced emergency tax measures to deal with the effects of the coronavirus (COVID-19) outbreak. In Uganda: taxpayers with an accounting period ending on 30 September...

You will often hear the saying that Amsterdam is the new London, referring to the tendency of South African-born Millennials to prefer the City of Sin to the capital of the British Empire...

As another Budget Speech looms, one can only hope that the Minister of Finance will provide positive news to encourage further investment in the oil and gas industry.

A number of tax rate increases were announced in the 2017 Budget Review on 22 February 2017. These may impact directly on investment yields and re-investment base of investors.

The Taxation Laws Amendment Bill confirms the introduction of interest withholding tax at a rate of 15% as from 1 January 2015 which applies in respect of interest that is paid or that becomes due and payable on or after that date.

In our Global Tax Alerts in February 2018 and January 2019 we discussed the Dutch Court of Appeal's decision which held that dividend distributions from Dutch entities to South African entities are effectively...

South Africa has a budget deficit of 3.1 % of GDP and debt on government spending alone amounting to a staggering 48% of GDP.

Dividends withholding tax ("DWT") was introduced into the Income Tax Act 58 of 1962 ("the Act") with effect from 1 April 2012.

The Cape Town Tax Court recently upheld the application of the so-called ‘most favoured nation clause' contained within the double tax agreement between South Africa and the Netherlands ("the SA-NL DTA").

Although the overall economics of share lending arrangements ("share loans") and repurchase arrangements ("repos") may be comparable in certain instances...

The draft Taxation Laws Amendment Bill, 2012 which was released by National Treasury on 5 July 2012 proposes to amend, the interest exemption contained in section 10(1)(h) of the Income Tax Act as from 1 January 2013.

Although the overall economics of repurchase arrangements ("repos") and collateral arrangements may be comparable in certain instances, the legal nature of these transactions...

On 12 June 2019, the Tax Court of South Africa delivered its judgment in ABC (Pty) Ltd v C:SARS (case no. 14287).

If not considered to be carrying on a trade, could the foreign exchange gains and losses on foreign debt instruments be considered to be interest?

The Foreign Accounts Tax Compliance Act had a very controversial reception by the global financial services community, and saw a robust lobbying effort against its more onerous obligations.

Internationally, intra-group financing arrangements have been under scrutiny for a number of years and have been the subject of some of the most significant transfer pricing disputes.