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ENSafrica | OECD, South Africa | 31 May 2022

ENSafrica tax in brief - Issue 83 | 2022-05

On 16 September 2021 at Skilpadhek, on the border to Botswana, the respondent (Commissioner) detained a truck and trailer that the applicant uses to…
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ENSafrica | OECD, South Africa | 17 May 2022

ENSafrica tax in brief - Issue 82 | 2022-05

The High Court of South Africa (Gauteng Division, Pretoria) | Bachan and Another v SARS Customs Investigations Unit and Others (19626/2022) [2022]…
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ENSafrica | South Africa | 3 May 2022

ENSafrica tax in brief - Issue 81 | 2022-05

The High Court of South Africa, Western Cape Division, Cape Town Ι Tunica Trading 59 (Proprietary) Limited v Commissioner, South African Revenue…
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ENSafrica | South Africa | 12 Apr 2022

SARS is fighting aGAAResively against “impermissible tax avoidance arrangements”: Considerations for taxpayers when entering into any form of transaction

Despite the crippling effects of the COVID-19 pandemic, the tide has turned and the South African Revenue Service (“SARS”) has collected ZAR1.884…
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ENSafrica | South Africa | 12 Apr 2022

SARS must also follow the Rules of the tax dispute resolution process

There are comprehensive rules promulgated under section 103 of the Tax Administration Act, 2011 (the "TAA" and the "Rules") which govern the tax…
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ENSafrica | OECD, South Africa | 29 Mar 2022

ENSafrica tax in brief - Issue 79 | 2022-03

Below, please find issue 79 of ENSafrica’s tax In Brief, a snapshot of the latest tax developments in South Africa.
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ENSafrica | OECD, South Africa | 15 Feb 2022

Transfer pricing, thin capitalisation and intra-group finance arrangements - SARS issues promised guidance in the form of draft interpretation note

Internationally, intra-group financing arrangements have been under scrutiny for a number of years and have been the subject of some of the most…
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ENSafrica | OECD, South Africa | 15 Jun 2021

ENSafrica tax in brief

The taxpayer appealed against the disallowance of his objection to a revised assessment imposed by the South African Revenue Service ("SARS"), which…
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Fasken | Netherlands, South Africa | 1 Jul 2019

A tale of three DTA’s: South African Tax Court confirms that no dividends tax is payable on distributions to Dutch resident shareholders

In terms of section 64E(1)(a) of the Income Tax Act 58 of 1962 ("the ITA") dividends tax at a rate of 20% must be paid when a South African company…
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DLA Piper | Netherlands, South Africa | 21 Jun 2019

South African Tax Court confirms application of the most favoured nation clause in the South Africa / Netherlands treaty

In our Global Tax Alerts in February 2018 and January 2019 we discussed the Dutch Court of Appeal's decision which held that dividend distributions…
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