There has been uncertainty around the tax treatment of fees paid to non-executive directors. While it is clear that the amounts will be subject to income tax, the question was when and how this tax should be collected.

A protocol amending the double tax agreement (DTA) between South Africa and Sweden took effect from 18 March 2012.

It appears as if interest in making use of the venture capital company tax incentive is increasing. BPR274 deals with an investment by a venture capital company in a solar electricity generation business.

A number of amendments proposed by the National Treasury are, if implemented in their current form, likely to significantly impact on trust structures.

Dividends paid by one South African company to another have been exempt from both normal tax and dividends tax since April 2012 when dividends tax came into effect.

Sections 8F and 8FA contain re-characterisation rules relating to hybrid debt instruments and hybrid interest.

Since the introduction of dividends tax in 2012, in particular the company to company exemption, taxpayers have employed a number of methods to convert taxable proceeds upon the sale of shares...

Interest is only deductible if incurred in the production of income and for purposes of carrying on a trade. This requires that the loan in respect of which the interest is paid and the trade/income...

A number of amendments made at the end of 2016 take effect from 1 March 2017. This includes amendments relating to PAYE.