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Corporate Tax News

[FAQ] Income tax deduction with regards to bursari...

A large corporation wishes to make bursaries available to its staff. They have been approached by a...


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[FAQ] Connected persons and the waiver of loans

Two companies with loan accounts between them are connected persons. The one company liquidated duri...


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[FAQ] Withholding tax calculation for foreign spor...

Foreign sportspersons are managed by a company in the Netherlands who invoices a South African compa...


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[FAQ] The term “consultant” when assessing the S12...

Company C has two sources of income streams – one does recruitment of candidates for the placement a...


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[FAQ] The issue of shares as payment for debt

South African Company A paid a supplier for goods delivered directly to Company B(based in Singapore...


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[FAQ] The deduction of expenses incurred when taki...

A taxpayer wants to take her staff and their families away for a few days as a team building/thank y...


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[FAQ] Shares held as trading stock

A company trades in shares. How will the share value gain be accounted for tax purposes? Would the s...


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Notice by SARS where financials were prepared for...

A new company prepared annual financial statements for 15 months which included the 3 months of its...


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BCR 075 - Settlement of post-retirement medical a...

This ruling determines the tax consequences for the employers and the qualifying employees due to th...


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Relevance of accounting standards to South Africa...

This article considers the relevance of the accounting treatment of transactions for South African t...


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BPR 353 – Linear adjustment of gross sales of unre...

This ruling determines that a linear adjustment may be made to adjust gross sales of an unrefined mi...


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Estimating the tax effects of the sale of a busine...

Tax practitioners are often asked to calculate the indicative effects of the prospective sale of a b...


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Managing exchange of information requests in trans...

Requests for information between tax authorities and requests for taxpayers to supply the informatio...


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Covid-19: How to manage 'place of effective manage...

Covid-19 is only anticipated to peak in South Africa (SA) in September 2020, with international air...


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Employment Revival Guide – Alert Level 4 Regulatio...

Alert Level 4 of the lockdown is geared toward the revival of economic activities and to allow emplo...


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Further tax measures for businesses to combat the...

In line with the President’s address to the nation on 21 April 2020, the Minister of Finance provide...


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Tax and Fiscal Policy in Response to the Coronavir...

The OECD released its report on Tax and Fiscal Policy in Response to the Coronavirus Crisis on 15 Ap...


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COVID-19: The UIF announces important updates to T...

Many businesses directly or indirectly impacted by the COVID-19 pandemic, have one problem in common...


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Proposal regarding COVID-19 disaster relief funds...

In this article the proposal regarding donations made to COVID-19 disaster relief funds is briefly d...


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GUIDELINES FOR APPLICATION: DEBT RELIEF FINANCE SC...

For Small Businesses in need of financial support during this difficult time, refer to the Debt Reli...


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Case Law: Telkom SA SOC Limited vs The Commissione...

A judgment handed down on March 25 by the Supreme Court of Appeal (SCA) held that a R3.9 billion for...


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Covid-19 and Tax

Monday 23 March 2020 will be remembered in the history books as the day that South Africa declared w...


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Comparable Tax Exemption (Section 9D(2A))

This amendment determines that the comparable tax exemption threshold be reduced to 67.5%.


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Value-Shifting Rules (Section 24BA and Section 40C...

Anti-avoidance principles preventing the transfer of high value assets to a company in return for lo...


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Enhancements to the ITR14 Company Income Tax Retur...

On 21 February 2020, SARS implemented enhancements to the ITR14 Company Income Tax Return.


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​Discussion paper on reviewing the tax treatment o...

Reviewing the Tax Treatment of Excessive Debt Financing, Interest Deductions and Other Financial Pay...


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Interpretation Note 44 (Issue 3) – Public Benefit...

This Interpretation Note provides guidance on the application and interpretation of paragraph 63A wh...


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SARS Guide on Venture Capital Companies

This guide provides users with general guidance on venture capital companies and investments in such...


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Draft Documents for Public Comment: Draft Binding...

The draft BGR provides clarity on what constitutes an unbundling transaction under section 46(1) of...


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OECD releases Transfer Pricing Guidance on Financi...

The OECD released the report "Transfer Pricing Guidance on Financial Transactions: Inclusive Framewo...


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Interpretation Note 75 (Issue 3) – Exclusion of ce...

This Interpretation Note provides guidance on the application of the proviso to the definition of “g...


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Will trusts still be the way to go? The new sectio...

Authors: Emil Brincker and Louis Botha


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South Africa's first transfer pricing case?

Author: Jerome Brink


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Global transfer pricing risk management

Author: Okkie Kellerman


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Treatment of transfer pricing secondary adjustmen...

Author: Grant Thornton South Africa


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Paragraph 51A relief deadline of 31 December 2012...

Posted by: SAIT Technical


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BPR 133: Transfer of a residence out of a company...

Posted by: SAIT Technical


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OECD’s base erosion and profit shifting action pla...

Author: Lisa Brunton


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Binding Private Ruling 133 (Tax Alert)

Posted by: SAIT Technical


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Non-submission of transfer pricing documentation i...

Authors: Karen Miller & Carryn Alexander


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Capital gains tax and the primary residence exemp...

Author: Mansoor Parker


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Procedure is everything

Author: Louis Botha


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Author: OECD

Author: OECD


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Disposals by share incentive trusts

Author: Heinrich Louw


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Professional tax advice vital in mitigation of pe...

Author: Andrew Lewis


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Could capital gains tax be increased?

Author: Ingé Lamprecht


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Could capital gains tax be increased?

Author: Ingé Lamprecht


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Additional taxes are in the pipeline

Author: Wiseman Khuzwayo


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Cross-issue of shares

Author: Heinrich Louw


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Matthew Lester unpacks wealth taxes in light of th...

Author: Matthew Lester


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Feedback from National Treasury workshop: Cross-is...

Author: Lesedi Seforo


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The implementation of BEPS - how it may all come...

Author: Esther Geldenhuys


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Capital gains tax deferred

Author: Ben Strauss


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New rules for cancellation of contracts

Authors: Denny da Silva and Elandre Brandt


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Scope of capital gains tax liability broadened

Authors: Gigi Nyanin and Nicole Paulsen


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Market value of shares on valuation date

Author: Heinrich Louw


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Determining the CGT base cost of shares in a priva...

Author: PwC South Africa


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Widening the scope of Capital Gains Tax liability

Author: Donatella Callaway


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A win against SARS: late delivery of SARS’s rule 3...

Author: Mareli Treurnicht


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Commercial property: three ways to save tax

Author: Ben Strauss


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Exempt dividends treated as income or proceeds fo...

Authors: Craig Miller and Joon Chong


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Closing window for tax and exchange control relief

Author: Scott Salusbury


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SARS issues binding class ruling regarding unbundl...

Authors: Tsanga Mukumba and Louis Botha


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Proposed amendments to clarify income tax treatme...

Authors: Robert Gad, Megan McCormack and others


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Tax exemption is not a formality – the Tax Court...

Authors: Louis Botha and Louis Kotze


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Timing of tax on gift cards

Author: Ben Strauss


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Proposed amendments to clarify income tax treatmen...

Authors: Robert Gad , Megan Mccormack And Jo-Paula Roman


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Controlled foreign company comparable tax thresho...

Author: Tsangadzaome Mukumba


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A creature of statute: A decision about the Tax C...

Authors: Louis Botha and Louis Kotze


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Unintended consequences of the new CFC rules

Author: Judith Becker


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New tax change taxes dividends in a collective in...

Author: Magda Snyckers


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Carbon Tax Bill: finalisation & voting; Financial...

Author: Parliamentary Monitoring Group


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Win for the employer: Judgment on the Employment T...

Authors: Louis Botha and Louis Kotze


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Important judgment for taxpayers regarding the va...

Author: Jerome Brink


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SA tax penalties on companies

Author: Nico Theron


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Disallowance of the utilisation of an assessed los...

Author: Gigi Nyanin


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No capital gains tax? Ruling on the disposal of p...

Author: Louis Botha


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Tax avoidance – when does it apply?

Author: Peter Dachs


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Ruling on customer loyalty programme

Author: Heinrich Louw


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No tax deduction for damages paid for deliberate b...

Authors: Ben Strauss and Jerome Brink


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Exchange Control: Recent amendments to the Currenc...

Author: Louis Botha


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Corporate reorganisations: the dividend stripping...

Authors: Nicolette Smit and Stephan Minne


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Accrual of amount on cession of right to dividends

Author: Ben Strauss


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A re-prioritising of sorts - between the anti-avo...

Author: Louis Botha


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A long-awaited guide on venture capital companies...

Author: Gigi Nyanin


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Controlled foreign companies: look before you leap

Authors: Carmen Gers and Simone Krupanandham S


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The capital v revenue question in the context of...

Authors: Louis Botha and Louise Kotze


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Carbon Tax Bill: Treasury response to submissions

Author: Parliamentary Monitoring Group


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Efficient or inept? South Africa’s corporate incom...

Author: Candice Gibson


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SARS issues binding class ruling regarding unbund...

Friday, 21 June 2019 Authors: Tsanga Mukumba and Louis Botha (Cliffe Dekker Hofmeyr) Important:...


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