Goodbye to the “loop structure” prohibition
BY NICOLETTE SMIT (First published on ENSight) In its typical form, a so-called “loop structure” arises where a South African exchange control resident (individual or company)…
Category: South Africa
SARS NON-COMPLIANCE WITH SECTIONS 42 AND 96 OF THE TAX ADMINISTRATION ACT, 2011
Letter from SAICA to SARS Please find attached SAICA’s submission to SARS regarding SARS’ non-compliance with sections 42 and 96 of the TAA. SARS have…
South Africa Advance Pricing Agreements – Discussion Paper
Published by SARS Multi-national enterprises (MNEs) play important roles around the world and even more so when they invest in developing countries (like South Africa),…
Key highlights from South Africa’s Minister of Finance 2020 Medium Term Budget Policy Statement
Article by: Regan van Rooy This year certainly continues to be a very interesting year for tax and exchange control. This week, Tito Mboweni, SA’s finance…
To Trust or not to Trust?
By: Regan van Rooy Is establishing an international trust still worth the tax trouble? As we have previously observed, there is little love lost between…
Court confirms the obligation on SARS to provide taxpayers with ample reasons
By: Conor McFadden – First published on Lexology The Constitution of the Republic of South Africa provides that ‘[e]veryone whose rights have been adversely affected by…
“Loop” structures and the controlled foreign company rules
Article by Carmen Gers, first published on Lexology One of the welcome announcements by the Minister of Finance in his budget speech delivered in February…
Key changes from Draft TLAB 2020
Article by: Regan van Rooy Please see below our summary of the key take-aways from draft tax legislation released by the South African National Treasury…
SARS targets foreign trusts for tax collection yet again
Article by: Regan van Rooy It is no secret that the South African Revenue Service (SARS) is suspicious of trusts, especially international ones. They are…
Judgment: Big G Restaurants vs SARS Full Judgment and Summary
Summary supplied by: Ms Deone Roos (Pieterse TRM Erasmus) Download the full judgment here: Summary