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The introduction of REITs

DLA Cliffe Dekker Hofmeyr
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South Africa
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July 13 2012

One of the welcomed aspects that is dealt with in the latest draft of the Taxation Laws Amendment Bill, 2012 (Bill) is the introduction of the long-awaited Real Estate Investment Trusts (REITs

Tax anomalies with odd-lot offers

DLA Cliffe Dekker Hofmeyr
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South Africa
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June 4 2012

An odd-lot offer is defined in the listing requirements of the Johannesburg Stock Exchange as an offer where a listed company intends reducing administrative costs resulting from a large number of "odd-lot" holders

Dividends tax and the beneficial owner - should a dividend be paid to a trust?

DLA Cliffe Dekker Hofmeyr
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South Africa
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April 20 2012

The issue pertaining to whether a trust is liable for dividends tax should a company pay a dividend to the trust as the registered owner of the shares has recently been clarified by SARS

Agreements entered into in haste may have resulted in undue fees and expenses

DLA Cliffe Dekker Hofmeyr
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South Africa
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March 16 2012

In the Budget Speech of 22 February 2012 it was announced that the Capital Gains Tax (CGT) rates would be increased

Recipient of royalties is also the beneficial owner the Velcro judgment

DLA Cliffe Dekker Hofmeyr
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Canada
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March 2 2012

The Tax Court of Canada handed down its long awaited judgment on whether the recipient of royalties was also the beneficial owner in the Velcro case on 24 February 2012

The conversion of par value shares into no par value shares for company law purposes

DLA Cliffe Dekker Hofmeyr
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South Africa
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January 13 2012

Since the introduction of the new Companies Act on 1 May 2011, consultants have battled with the problem as to whether the conversion of par value shares by a company into no par value shares will result in a tax liability for purposes of the Eighth Schedule to the Income Tax Act, No 58 of 1962 (the Act

Retrospective legislation not always objectionable

DLA Cliffe Dekker Hofmeyr
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United Kingdom
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July 29 2011

The Court of Appeal (Civil Division) gave judgment on 25 July 2011 in the matter of Huitson v HMRC, pertaining to the retrospective legislation that was introduced by the revenue authorities in relation to a so-called tax avoidance scheme that was operated by the taxpayer through means of the Isle of Man

Pay now, argue later - some further developments

DLA Cliffe Dekker Hofmeyr
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South Africa
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July 1 2011

Despite having entered an objection against an assessment, or having noted an appeal against the disallowance of such objection, it is a reality that a taxpayer may be met by the sheriff, on his doorstep, ready to enforce payment of the amount of tax allegedly due to SARS

The guillotine has fallen for realisation companies

DLA Cliffe Dekker Hofmeyr
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South Africa
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May 13 2011

The Supreme Court of Appeal (SCA) gave judgement in favour of SARS on 10 May 2011 in the case of CSARS v Founders Hill dealing with the activities of a realisation company that was formed by AECI Limited (AECI

The IBM case - whether all payments made in terms of a software licence agreement constitute royalties for purposes of a treaty

DLA Cliffe Dekker Hofmeyr
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Australia
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May 6 2011

The Federal Court of Australia on 12 April 2011 gave a far-reaching judgment in the case of International Business Machines Corporation (IBM) v COT dealing with the question whether all payments made by IBM to its US holding company constituted royalties for purposes of the Treaty concluded between Australia and the USA

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