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S.Africa: SARS have introduced a new modernised tax return for Trusts

S.Africa: SARSThe South African Revenue Service (SARS) is the official tax authority responsible for the administration and enforcement of tax laws in South Africa. It plays a crucial role in managing the country’s fiscal policy by collecting revenue, administering customs, and ensuring compliance with tax legislation. Established under the South African Revenue Service Act, No. […]

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S.Africa: Missed the NEW TAA Dispute Resolution seminar – here is the recording

Missed the NEW TAA Dispute Resolution seminar Here is the recorded version: I delivered a 4 hour detailed seminar on the NEW TAA Dispute Resolution rules (end Sept 2014) that will affect you as tax practitionerA Tax Advisor is a professional who provides specialised advice to individuals, businesses, and organisations on various tax-related matters. They

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BRICS: Potential influence in Africa of China beneficial ownership case where preferential dividend rate denied – WITH further explanations applicable to Africa

BRICS: Potential influence in Africa of China beneficial ownership case where preferential dividend rate denied – WITH further explanations applicable to Africa Latest Chinese tax case on beneficial ownership in treaty application Abe ZhaoTax Partner, Head of International Tax of KPMG Asia Pacific Region, Country Leader of KPMG China’s International Tax Tax officials in Qinghai,

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S.Africa: Customs & Excise reclassification – importance of evidence

http://www.saflii.org/za/cases/ZASCA/2013/145.html Bowman Gilfillan Virusha Subban September 19 2014 The Supreme Court of Appeal recently ruled on the correct customs duty classification for a vehicle known as a Kubota RTV Utility Vehicle.Facts The competing tariff headings in this case were: TH 87.04 for motor vehicles for the transport of goods (Subheading 8704.21.80); and TH 87.09 for

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S.Africa: Disposal of foreign equity shares – proceed with caution

Disposal of foreign equity shares – proceed with caution ENSafrica Peter Dachs and Bernard Du Plessis South Africa September 16 2014 In advising on international corporate transactions we often advise taxpayers that directly, or indirectly through a foreign subsidiary, dispose of their equity shares in foreign subsidiaries or equity investments resulting in a taxable capital gain. What

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Mauritius: Mauritius further enhances its position as an offshore jurisdiction of choice with 4 new DTAs

Article by Malcolm Moller and Sharmilla Bhima Appleby  The Government of the Republic of Mauritius (Government of Mauritius) has ratified double taxationDouble Taxation occurs when the same income or financial transaction is taxed twice, typically in different jurisdictions. It can arise in two primary contexts: economic double taxation, where the same income is taxed twice in the hands

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OECD: Seven BEPS Actions issued September 16, 2014

COMMENT BY DR. D.N. ERASMUS – This is a summary of an article first published in a Bloomberg BNA Transfer PricingTransfer pricing is a fundamental concept in international taxation that defines the pricing methods and rules applied to transactions between related entities within a multinational enterprise (MNE). In the context of tax regulations, it governs

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S.Africa: Proposed changes to secondary transfer pricing adjustment

DLA Cliffe Dekker Hofmeyr Heinrich Louw South Africa September 12 2014 National Treasury and the South African Revenue ServiceThe South African Revenue Service (SARS) is the official tax authority responsible for the administration and enforcement of tax laws in South Africa. It plays a crucial role in managing the country’s fiscal policy by collecting revenue,

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OECD: First recommendations for combating international tax avoidance by multinational enterprises on Tuesday 16 September 2014

http://www.oecd.org/tax/oecd-to-release-first-recommendations-for-combating-international-tax-avoidance-by-multinational-enterprises-on-tuesday-16-september-2014.htm OECDThe Organisation for Economic Co-operation and Development (OECD) is an international organisation comprising 38 member countries, established to foster economic growth, trade, and development on a global scale. Founded in 1961, the OECD provides a forum for governments to collaborate, share policy experiences, and develop solutions to common economic challenges. The OECD’s core mission

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S.AFRICA: Expenditure relating to deferred accruals

Expenditure relating to deferred accruals DLA Cliffe Dekker Hofmeyr Heinrich Louw South Africa September 5 2014 Background The taxpayer operated a mine. Firstly, it would extract mineral ore from the earth, and secondly, by smelting and other processes, it would extract a concentrate (containing the minerals) from the ore. The taxpayer sold the concentrate to

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