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Results: 1-10 of 20

Unintended consequences of the new CFC rules
  • ENSafrica
  • South Africa
  • October 9 2017

In the 2017 South African Budget Speech, the Minister of Finance raised Government’s concern that the current Controlled Foreign Company (“CFC”) rules


South African draft tax amendment targets share buybacks
  • ENSafrica
  • South Africa
  • August 16 2017

The first draft Taxation Laws Amendment Bill, 2017 (the “2017 TLAB”) was released on 19 July 2017 for public comment (due by 18 August 2017). Among


The future taxation of trusts
  • ENSafrica
  • South Africa
  • June 26 2013

In the National Budget, tabled in Parliament on 27th February 2013, the Minister of Finance indicated that government was proposing several


Forum on Tax Administration - Moscow meeting
  • ENSafrica
  • South Africa, Global
  • May 29 2013

The Forum on Tax Administration ('FTA'), comprising the heads of tax administrations from 45 economies, met in Moscow for the 8th meeting of the FTA


Tax planning as part of corporate social responsibility
  • ENSafrica
  • South Africa
  • June 30 2011

Recently UK development agencies changed their strategy of lobbying governments and international bodies on the harmful effects of tax avoidance by multinationals in the developing world, to targeting the companies themselves


The unintended consequences of Section 12N
  • ENSafrica
  • South Africa
  • May 30 2011

Prior to the introduction of section 12N, section 11(g) of the Act regulated any deductions related to leasehold improvements


Another arrow in SARS’ quiver
  • ENSafrica
  • South Africa
  • February 15 2011

Few tax cases in recent years have evoked as much interest as the recent case of CSARS v NWK, in which the Supreme Court of Appeal (SCA) expanded the accepted interpretation to the legal doctrine of substance over form


The law of unintended consequences Section 24J of the Income Tax Act
  • ENSafrica
  • South Africa
  • October 28 2010

Consider a situation where Company A, Company B and Company C form part of a group of companies, Company A advances an interest bearing loan to Company B which, in turn, advances an interest bearing loan to Company C as part of a single arrangement


Employee share incentive schemes: the stop loss anomaly
  • ENSafrica
  • South Africa
  • October 4 2010

Employee share incentive schemes are ordinarily implemented by Employer Companies in order to incentivise and retain employees ("Participants") and for such Participants to receive indirect benefits from the appreciation in the growth of such company


Proposed changes to the interest exemption for non-residents will have far reaching and unintended implications
  • ENSafrica
  • South Africa
  • June 22 2010

In terms of the current law, interest earned by non-resident lenders from South African ("SA") resident borrowers is generally exempt from SA income tax