On 22 July 2015, National Treasury issued draft legislation for public comment.  The legislative amendments seek to implement the tax proposals announced in the 2015 Budget Speech.  Comments are due by 24 August 2015.

The changes proposed are numerous and, in some cases, will have far-reaching effects.  For example, the controlled foreign company legislation will be changed to reintroduce the previously deleted diversionary rules.  In addition, section 6quin, which caters for foreign tax credits for service fees sourced in South Africa, is to be deleted.  This may have contractual implications, specifically regarding the gross up of any service fees to cater for the removal of the foreign tax credit.

It is noted that at this stage no amendments are introduced following the Davis Tax Committee report on estate duty and the suggested changes to the taxation of trusts.