Interpretation of fiscal legislation DLA Cliffe Dekker Hofmeyr Emil Brincker South Africa November 28 2014 The judgment of the Supreme Court of Appeal in Commissioner SARS v Bosch (394/2013) [2014] ZASCA 171 (19 November 2014) (Bosch case) dealing with the fiscal consequences of a deferred delivery transaction is not only important in the context of the meaning of simulation, […]
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the thin capitalisation provisions of section 23M and further amendments proposed thereto by Okkie Kellerman and Esther Geldenhuys In line with recent pronouncements by the OECD relating to so-called Base Erosion and Profit Shifting Project (BEPS), section 23M was introduced by the Taxation Laws Amendment Act, 31 of 2013. Section 23M of the Income Tax Act, 58 of 1962 (“the
Landmark judgment in Supreme Court of Appeal upholds deferred delivery share scheme Commissioner SARS v Bosch (394/2013) [2014] ZASCA 171 (19 November 2014)Share option scheme – s 8A(1)(a) of the Income Tax Act 58 of 1962 – employees given option to purchase shares – option to be exercised within 21 days – payment for and delivery of shares to occur in tranches two, four and six
Here are the copies of the following Bills introduced in Parliament:- 1. Taxation Laws Amendment Bill 2. Rates and Monetary Amounts and Amendment of Revenue Laws Bill 3. Tax Administration Laws Amendment Bill b 12-2014 (rates & monetary amounts) b 13-2014 (taxation laws) b 14-2014 (tax administration laws)
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Preservation orders DLA Cliffe Dekker Hofmeyr Heinrich Louw South Africa October 17 2014 Here is the actual judgment: SA Tax Cases Tradex Pty Ltd 9 September 2014 Judgment was recently handed down in the High Court (Western Cape Division) in the matter of Commissioner for the South African Revenue Service v Tradex (Pty) Ltd and others (9 September
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Zimbabwe tax system in a nutshell Celia Becker ENSafrica, South Africa Celia Becker is Tax Advisor at ENSafrica in Johannesburg. I. Background The Zimbabwean tax system is sourced-based, with a standard corporate income tax rate of 25 percent and maximum personal income tax rate of 45 percent. A three percent AIDS levy is imposed on both corporate and personal income tax The disposal of
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Botswana tax system in a nutshell Celia Becker ENSafrica, South Africa Celia Becker is an Africa regulatory and business intelligence executive at ENSafrica in South Africa. I. Background The tax regime in Botswana consists of a number of direct and indirect taxes including income tax, VAT, import duty and excise duty. The Botswana tax system
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Proposed Changes to Secondary Transfer Pricing Adjustment South Africa’s National Treasury and the South African Revenue Service (SARS) recently released the draft Taxation Laws Amendment Bill 2014 (Bill). One of the key proposals in the Bill is to change the secondary transfer pricing adjustment mechanism from a deemed loan to a deemed dividend. Transfer pricing
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http://www.justice.gov.za/sca/judgments/sca_2014/sca2014-157.pdf For a summary of the case: http://www.justice.gov.za/sca/judgments/sca_2014/sca2014-157ms.pdf A short radio interview giving the basics of the case: https://www.youtube.com/watch?v=yDftRV8uWYY&feature=youtu.be Shuttleworth could have ‘shuttled’ his monies out of South Africa without the payment of a levy DLA Cliffe Dekker Hofmeyr Emil Brincker South Africa October 3 2014 In a far reaching judgment the Supreme Court of
Nigeria: Interest On Intercompany Loan Incurred By An Oil Company Is Tax Deductible Subject To Transfer Pricing Rules Last Updated: 30 September 2014 Article by Taiwo Oyedele PwC Nigeria The Tax Appeal Tribunal (TAT) on 18 September 2014 passed a judgement in a case between Nigeria Agip Oil Company Limited and the Federal Inland Revenue Service (FIRS) regarding the
