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Results: 1-10 of 168

Source of pension benefits relating to offshore services
  • ENSafrica
  • South Africa
  • October 6 2011

There is some uncertainty regarding the current tax treatment of private sector pension benefits derived by South African tax residents in respect of services which were rendered both inside and outside South Africa, particularly in respect of the source of such benefits


Intellectual property companies and substance: think before you jump!
  • ENSafrica
  • South Africa
  • July 4 2011

The decision in the recent Oilwell case may cause multi-national enterprises (“MNE”) to again consider moving their Intellectual Property (“IP”) offshore


Tax may dampen expansive new judgement on offshore assignment of intellectual property
  • ENSafrica
  • South Africa
  • April 5 2011

The Supreme Court of Appeal, in the case of Oilwel (Pty) Ltd v Protec International & Others ("the Oilwel Appeal"), has finally ruled on the issue of the assignment of intellectual property from a South African Resident


Capital gains tax & the creation of assets
  • ENSafrica
  • South Africa
  • April 30 2012

In terms of the Eighth Schedule to the Income Tax Act (the “Act”) capital gains tax (“CGT”) is levied in respect of the “disposal” of any “asset” by a person


Residential property amnesty renovations concluded!
  • ENSafrica
  • South Africa
  • October 28 2010

After representations were made to the National Treasury with respect to the introduction of a residential property amnesty, it appears that the final version of the legislation has been 'renovated' to suit the array of family planning structures and circumstances currently being utilised


Transfer of holiday homes trapped in trusts or companies
  • ENSafrica
  • South Africa
  • August 12 2011

In current law, a concession exists for the transfer of residences out of companies or trusts providing relief from capital gains tax and other taxes


Taxation of offshore trusts
  • Shepstone & Wylie Attorneys
  • South Africa
  • October 15 2015

Extensive use has been made of trusts in South Africa, both for tax planning and for the purposes of reducing (or eradicating) one's estate duty


SARS looks to clear up misconceptions relating to tax exemption for foreign employment income
  • Cliffe Dekker Hofmeyr
  • South Africa
  • March 4 2016

The South African Revenue Service (SARS) issued Draft Interpretation Note 16 (Issue 2) (Draft IN) for public comment recently. When compared to the


Trust taxation
  • Cliffe Dekker Hofmeyr
  • South Africa
  • August 19 2015

The first interim report on estate duty to the Minister of Finance by the Davis Tax Committee (Committee), which was made public on 13 July turned its


Settlors beware: control over the assets of a trust
  • ENSafrica
  • South Africa
  • February 17 2016

The establishment of an offshore discretionary trust ("the Trust") by a South African tax resident person ("Settlor") gives rise to various South