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Results: 1-10 of 37

Preference shares constituting equity shares

  • DLA Cliffe Dekker Hofmeyr
  • -
  • South Africa
  • -
  • 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

Piercing the corporate veil has been extended

  • DLA Cliffe Dekker Hofmeyr
  • -
  • South Africa
  • -
  • March 15 2013

The recognition of a company as a separate juristic person, liable for its own tax (or other) debts, is an important principle relied on by taxpayers

Cross issue of shares

  • DLA Cliffe Dekker Hofmeyr
  • -
  • South Africa
  • -
  • February 27 2013

Section 24B of the Act was initially introduced to deal with the acquisition of assets through the issue of shares. Pursuant to the judgment of CIR v

Share schemes

  • DLA Cliffe Dekker Hofmeyr
  • -
  • South Africa
  • -
  • February 27 2013

Share incentive schemes are once again in the spot light in this year's tax budget proposals. It appears that previous amendments have not satisfied

Tax: final interpretation note on the Brummeria judgment

  • DLA Cliffe Dekker Hofmeyr
  • -
  • South Africa
  • -
  • July 20 2010

When the judgment of the CSARS v Brummeria Renaissance (Proprietary) Limited & Others was released in 2007 there were a number of taxpayer's and tax consultants experiencing restless nights

Transfer of place of registration under the new Companies Act

  • DLA Cliffe Dekker Hofmeyr
  • -
  • South Africa
  • -
  • May 6 2011

Any respite that corporate advisers enjoyed over the April public holidays was short lived when they returned to work under a new corporate law environment with the introduction of the new Companies Act No 71 of 2008 (the Companies Act) which came into effect on 1 May 2011

New life for South Africa's headquarter company regime

  • DLA Cliffe Dekker Hofmeyr
  • -
  • South Africa
  • -
  • November 6 2011

With effect from 1 January 2011, a new tax regime, regarding headquarter companies was enacted in the Income Tax Act 58 of 1962 (the Act) to ensure that the tax system did not act as a barrier to the use of South Africa as regional headquarter company (HQC), especially for Sub-Saharan Africa

Conversion of a public company to a private company

  • DLA Cliffe Dekker Hofmeyr
  • -
  • South Africa
  • -
  • March 30 2012

The South African Revenue Service has released a number of binding class and private rulings of late

Dividends ceded to companies not exempt from income tax

  • DLA Cliffe Dekker Hofmeyr
  • -
  • South Africa
  • -
  • March 2 2012

Dividends are generally exempt from income tax, subject to the exceptions contained in s10(1)(k)(i) of the Income Tax Act, No 58 of 1962 (the Act

Share schemes - repurchasing shares at the original subscription price

  • DLA Cliffe Dekker Hofmeyr
  • -
  • South Africa
  • -
  • July 30 2010

Binding Class Ruling No. 21 (BCR 21) dealing with the application of section 8C of the Income Tax Act (the Act) was released by the South African Revenue Service (SARS) earlier this week

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