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Allowances under section 11(e) assets forming part of a sale and leaseback arrangement

DLA Cliffe Dekker Hofmeyr
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South Africa
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May 17 2013

The South African Revenue Service (SARS) issued Binding Private Ruling 145 (ruling) on 8 May 2013. The ruling deals with the tax treatment of assets

Consideration received for the surrender of a right to acquire shares under section 8c

DLA Cliffe Dekker Hofmeyr
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South Africa
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May 17 2013

The South African Revenue Service (SARS) issued Binding Private Ruling 147 (ruling) on 14 May 2013. It deals with the tax treatment of compensation

Information-gathering and tax audits by a revenue authority could there be an ulterior purpose?

DLA Cliffe Dekker Hofmeyr
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Canada
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May 10 2013

The Canadian Federal Court of Appeal's (FCA) recent judgment in MNR v RBC Life Insurance Co, 2013 FCA 50 (decided on 21 February 2013) condemned the

Preference shares constituting equity shares

DLA Cliffe Dekker Hofmeyr
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South Africa
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May 10 2013

A very interesting binding private ruling was released by the South African Revenue Service (SARS) on 2 May 2013. Binding Private Ruling 143 (BPR

STC credits and new binding class ruling

DLA Cliffe Dekker Hofmeyr
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South Africa
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May 3 2013

The Dividends Tax regime was implemented just over a year ago on 1 April 2012. As part of the transitional arrangements from Secondary Tax on

New proposals on recharacterisation of hybrid debt instruments

DLA Cliffe Dekker Hofmeyr
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South Africa
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May 3 2013

National Treasury (Treasury) and the South African Revenue Service (SARS) recently released certain proposed limitations on excessive interest

Voluntary disclosure under the Tax Administration Act

DLA Cliffe Dekker Hofmeyr
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South Africa
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April 26 2013

The Tax Administration Act, No 28 of 2011 (TAA) provides for a permanent Voluntary Disclosure Programme (VDP) in ss225 - 233 (part B of chapter 16

Search and seizure: with or without a warrant?

DLA Cliffe Dekker Hofmeyr
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South Africa
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April 26 2013

A recent case in the Western Cape High Court has significant implications for SARS’s power to conduct search and seizure operations in terms of the

New Binding Private Ruling (BPR 141) - transfers from untaxed policy holder funds

DLA Cliffe Dekker Hofmeyr
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South Africa
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April 19 2013

The South African Revenue Service (SARS) issued a new Binding Private Ruling (BPR) on 28 March 2013 on the "Transfer of Securities from an untaxed

Understatement penalty: when can SARS potentially allege 'gross negligence' or 'intentional tax evasion'?

DLA Cliffe Dekker Hofmeyr
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Australia, South Africa
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April 19 2013

The Tax Administration Act, No 28 of 2011 (TAA) introduces the 'understatement penalty' in Chapter 16. Section 223 contains an 'understatement

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Allowances under section 11(e) assets forming part of a sale and leaseback arrangement

Consideration received for the surrender of a right to acquire shares under section 8c

Information-gathering and tax audits by a revenue authority could there be an ulterior purpose?

Preference shares constituting equity shares

STC credits and new binding class ruling

New proposals on recharacterisation of hybrid debt instruments

Voluntary disclosure under the Tax Administration Act

Search and seizure: with or without a warrant?

New Binding Private Ruling (BPR 141) - transfers from untaxed policy holder funds

Understatement penalty: when can SARS potentially allege 'gross negligence' or 'intentional tax evasion'?

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