South African Tax Guide

[...] requirements, exempt from normal tax in South Africa in terms of section 10(1)(o)(ii) of the Income Tax Act, No. 58 of 1962 (the Act). The general rule is that income earned by a tax resident of South [...]

[...] first and much anticipated judgement in relation to the interpretation of section 8A of the Income Tax Act, and to Deferred Delivery Share Schemes, a full bench of the Supreme Court of Appeal [...]

[...] should be interpreted. In Bosch, the question arose as to the meaning of Section 8A of the Income Tax Act (58/1962), which read that a taxpayer’s income should include any gain made by the exercise, [...]

[...] tax in South Africa, for example non-residents. The section in question, section 23M of the Income Tax Act, intends to protect the South African tax base by limiting such deduction. Views have been [...]

[...] Author: Peter Dachs – ENSafrica The concept of base erosion and profit shifting (BEPS) has been debated at various international forums following [...]

[...] Author:Peter Dachs – Tax Director at ENSafrica The concept of base erosion and profit shifting (“BEPS”) has been much discussed at various international forums including [...]

[...] In Part A of this article we provided an overview of the Base Erosion and Profit Shifting (‘BEPS’) Action Plan and listed the 7 action points which were released by [...]

[...] The Base Erosion and Profit Shifting (BEPS) Project is high on the agenda of the South African Government. [...]

[...] The Organisation for Economic Co-operation and Development (OECD) Base Erosion and Profit Sharing (BEPS) Action Plan, approved by the [...]

[...] Author: Lisa Brunton (DLA Cliffe Dekker Hofmeyr) The Organisation for Economic Co-operation and Development (OECD) Base Erosion and Profit Sharing (BEPS) Action Plan, approved by the [...]

[...] Author: Lisa Brunton The Organisation for Economic Co-operation and Development (OECD) Base Erosion and Profit Sharing (BEPS) Action Plan, approved by the [...]

[...] The Organisation for Economic Co-operation and Development (OECD) Base Erosion and Profit Sharing (BEPS) Action Plan, approved by the [...]

[...] to tax jurisdictions where there is little or no real business activity. Typically,Continue reading Continue reading → [...]

[...] that a seller of a business should not be under the impression that the absence,Continue reading Continue reading → [...]

[...] ”). Foreign SubCo would accordingly constitute a controlled foreign company (“CFC”)Continue reading Continue reading → [...]

[...] from the agencies in more doubt, though in the medium run Moody’s (and others)Continue reading Continue reading → [...]

[...] of 1962 (the Act) contained the prescription provisions prior to the enactment of theContinue reading Continue reading → [...]

[...] 47 of the Act, the definition of a ‘group of companies’ is more restrictive than theContinue reading Continue reading → [...]

[...] requests for clarity regarding the income tax treatment, of both the seller and theContinue reading Continue reading → [...]

[...] important change in the TLAB amends the definition of ‘controlling relationship’. TheContinue reading Continue reading → [...]

[...] Bill, 2014 (the Bill) confirms the speculation around the postponement of the changes to the tax treatment of retirement savings. The changes were set to impact the tax treatment of contributions to [...]

[...] (University of Stellenbosch) This article highlights principles that might be used for the tax treatment of client loyalty programme transactions in the hands of the supplier.  Function and types of [...]

[...] the tax concessions available to them. Venture capital companies – the investment process The tax treatment of the investors Who are the investors? Investors in VCCs may be individuals or corporate [...]

[...] paper in which it set out its application of the relevant tax law, in relation to the tax treatment of the purchaser and seller, with regard to the assumption of contingent liabilities as part [...]

[...] avoidance by multinational enterprises (MNEs) through artificially shifting profits to low tax jurisdictions and eroding the tax bases of their primary high tax jurisdictions of operation. The [...]

[...] strategies to artificially exploit gaps and mismatches in tax rules to shift profits to tax jurisdictions where there is little or no real business activity. Typically,Continue reading Continue [...]

[...] avoidance by multinational enterprises (MNEs) through artificially shifting profits to low tax jurisdictions and eroding the tax bases of their primary high tax jurisdictions of operation. The [...]

[...] avoidance by multinational enterprises (MNEs) through artificially shifting profits to low tax jurisdictions and eroding the tax bases of their primary high tax jurisdictions of operation. The [...]

[...] and endorsed by the G20 Heads of Government in September 2013, was formulated to combat international tax avoidance by multinational enterprises (MNEs) through artificially shifting profits to low tax [...]

[...] and endorsed by the G20 Heads of Government in September 2013, was formulated to combat international tax avoidance by multinational enterprises (MNEs) through artificially shifting profits to low tax [...]

[...] and endorsed by the G20 heads of government in September 2013, was formulated to combat international tax avoidance by multinational enterprises (MNEs) through artificially shifting profits to low tax [...]

[...] and endorsed by the G20 Heads of Government in September 2013, was formulated to combat international tax avoidance by multinational enterprises (MNEs) through artificially shifting profits to low tax [...]

[...] and Development (OECD) Base Erosion and Profit Sharing (BEPS) Action Plan, approved by the OECD Committee of Fiscal Affairs (CFA) in June 2013 and endorsed by the G20 Heads of Government in September [...]

[...] and Development (OECD) Base Erosion and Profit Sharing (BEPS) Action Plan, approved by the OECD Committee of Fiscal Affairs (CFA) in June 2013 and endorsed by the G20 Heads of Government in September [...]

[...] and Development (OECD) Base Erosion and Profit Sharing (BEPS) Action Plan, approved by the OECD Committee of Fiscal Affairs (CFA) in June 2013 and endorsed by the G20 heads of government in September [...]

[...] and Development (OECD) Base Erosion and Profit Sharing (BEPS) Action Plan, approved by the OECD Committee of Fiscal Affairs (CFA) in June 2013 and endorsed by the G20 Heads of Government in September [...]