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Registered address: 188 Fleet Street, London, EC4A 2AG

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Your search for ‘ENS’ returned 4,098 results

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  • Article

    Global Transfer Pricing Risk Management

    It is important to identify individuals within a multinational group who understand transfer pricing and ensure that there is constant communication between these individuals.
    South AfricaTax
    ENS
    ENS
  • Article

    Income Tax Notice Raises New Administrative Risk For Non-Resident Companies

    Section 66 of the Income Tax Act No. 58 of 1962 requires the Commissioner to give public notice annually of the prescribed time period within which persons who are liable to taxation under the Act must furnish their tax returns.
    South AfricaTax
    ENS
    ENS
  • Article

Interest-ing Finance Charges In Section 24J

In the Tax Court judgment of Taxpayer A v Commissioner for the South African Revenue Service IT 25042, the taxpayer wanted a deduction for finance charges under section 24J of the Income Tax Act, 1962 in its ...
South AfricaTax
ENS
ENS
  • Article

    Loop Structures Are No Longer Prohibited In South Africa

    From 1 January 2021, there is no longer a prohibition on loop structures in South Africa. This is a significant exchange control relaxation...
    South AfricaTax
    ENS
    ENS
  • Article

    Mauritius Supreme Court Sheds Some Light On Priority Of Tax Claims In Liquidations

    In The Car Company Ltd (in Liquidation) v. The Mauritius Revenue Authority, the Commercial Division of the Supreme Court ruled that the amount of taxes due under the Value Added Tax Act and the Income Tax Act ..
    South AfricaTax
    ENS
    ENS
  • Article

    OECD Request For Input On The Development Of A Multilateral Instrument To Implement Tax Treaty BEPS Measures

    Many of the BEPS outputs relate to tax treaties and will not be effective until the relevant bilateral tax treaties are amended.
    South AfricaTax
    ENS
    ENS
  • Article

    Pitfalls Arising From The Financial Provision For Mining Rehabilitation

    Mining companies generally make financial provision for rehabilitation by virtue of rehabilitation trusts or financial guarantees through a financial institution or insurance policies.
    South AfricaTax
    ENS
    ENS
  • Article

    Registration Requirements For Foreign Suppliers Of Electronic Services Clarified

    VAT legislation has been amended with effect from 1 April 2014 to require all foreign suppliers of electronic services in South Africa to register for VAT.
    South AfricaTax
    ENS
    ENS
  • Article

    SCA Decision In CSARS v Spur Group (Pty) Ltd

    Taxpayers who have made contributions to, in particular, share incentive trusts and claimed a deduction under section 11(a) of the Income Tax Act, 1962 ("the Act") on the basis that such payment was, inter alia, aimed at creating a "happy and contented" workforce.
    South AfricaTax
    ENS
    ENS
  • Article

    Share Loans And Repos: A South African Tax Perspective

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

    South African Draft Tax Amendment Targets Share Buybacks

    In the 2016 Budget Review, tax avoidance schemes involving share buybacks were highlighted for review.
    South AfricaTax
    ENS
    ENS
  • Article

    Tax In Brief | Issue 31

    the taxpayer disputed, inter alia, the correctness of additional estimated assessments issued by SARS.
    South AfricaTax
    ENS
    ENS
  • Article

    The Controversial Panama Papers – A South African Perspective

    The Panama Papers represent a leak of some 11.5 million files from a Panamanian based advisory firm, Mossack Fonseca.
    South AfricaTax
    ENS
    ENS
  • Article

    The Implementation Of BEPS - How It May All Come Together

    The Final Report on Action 15 explores the feasibility of developing a multilateral instrument that would have the same effect as a simultaneous renegotiation of thousands of bilateral tax treaties.
    South AfricaTax
    ENS
    ENS
  • Article

    The Proposed Amendments To The Non-Resident Interest Exemption

    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.
    South AfricaTax
    ENS
    ENS
  • Article

    The Valuation Of A Usufruct For Tax Purposes

    The value of a usufruct (which is the right to use property and enjoy it's profits without directly owning it) is often needed to be calculated for purposes of taxes.
    South AfricaTax
    ENS
    ENS
  • Article

    The VDP And Re-Submission Of Tax Returns

    The Voluntary Disclosure Programme ("VDP") formally closed on 31 October 2011.
    South AfricaTax
    ENS
    ENS
  • Article

    Unilateral Extension Of Prescription In Certain Specific Tax Matters

    In an ENSafrica article dated 19 August 2015, we addressed the proposed unilateral extension of prescription by SARS as was provided for in the draft Tax Administration Laws Amendment Bill...
    South AfricaTax
    ENS
    ENS
  • Article

    Unreported Judgment With Case Number: SARS 4/2013

    Tuchten J of the North Gauteng High Court handed down an important judgment in relation to information and documentation obtained by SARS.
    South AfricaTax
    ENS
    ENS
  • Article

    When Is A Prepayment Consideration For A VATable Supply?

    We recently wrote about the fact that Her Majesty Revenue & Customs ("HMRC") updated their guidance and practice in the United Kingdom regarding the VAT status of forfeited deposits, following a judgment of the European Court of Justice ("ECJ") (ECJ Case C-277/05).
    South AfricaTax
    ENS
    ENS
  • Showing 761–780 of 4098 results

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