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Tax on foreign employment income likely to change
- ENS - Edward Nathan Sonnenbergs
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- South Africa
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- May 1 2013
Changes are being proposed to the foreign earnings exemption which may potentially affect South African tax liability in relation to foreign-earned
Confidentiality provisions under the Tax Administration Act
- ENS - Edward Nathan Sonnenbergs
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- South Africa
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- April 25 2013
This article considers the scope of the new confidentiality provisions contained in the Tax Administration Act 28 of 2011 ("Admin Act") and how such
Income tax notice raises new administrative risk for non-resident companies
- ENS - Edward Nathan Sonnenbergs
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- South Africa
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- April 25 2013
Section 66 of the Income Tax Act No. 58 of 1962 ("the Act") requires the Commissioner to give public notice annually of the prescribed time period
Creating value through Business Model Optimisation
- ENS - Edward Nathan Sonnenbergs
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- South Africa
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- April 25 2013
Business Model Optimisation ('BMO') is a process whereby value is created through business transformation. It is essentially a methodology which
Capital gains tax and the primary residence exemption
- ENS - Edward Nathan Sonnenbergs
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- South Africa
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- April 25 2013
Is it true that globally mobile employees can sell their homes and not pay capital gains tax even if they rented it out for a number of years? It is
The potential implications if a taxpayer is seen to have dissipated its assets
- ENS - Edward Nathan Sonnenbergs
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- South Africa
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- April 25 2013
The Tax Administration Act No. 28 of 2011 ("Tax Administration Act") deals with tax administration only and serves as a consolidated piece of
The implementation of a full group taxation system in South Africa
- ENS - Edward Nathan Sonnenbergs
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- South Africa
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- April 25 2013
Over the last several years, the government has taken significant steps to improve the competitiveness of the tax system for South African businesses
The imaginary world of notional vendor finance
- ENS - Edward Nathan Sonnenbergs
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- South Africa
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- March 19 2013
Many share acquisition transactions implemented in South Africa are vendor financed, i.e. money is lent by the company to a prospective shareholder
Recent case on judicial review of SARS’ actions in terms of PAJA
- ENS - Edward Nathan Sonnenbergs
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- South Africa
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- March 19 2013
The South African Revenue Service ("SARS") increased their audit activity and focus on the collection of tax. Taxpayers often rely on protection in
Changes to the taxation of dividend cessions and manufactured dividends
- ENS - Edward Nathan Sonnenbergs
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- South Africa
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- March 19 2013
In the 2013 Budget Review, which was released on 27 February 2013, specific mention was made that a research project is underway in which
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