Entries by tax consulting

Implementation of the Foreign Account Tax Compliance Act (FATCA) in South Africa

Background, aims and enactment of FATCA The Foreign Account Tax Compliance Act (colloquially known as “FATCA”) was enacted by the United States government during 2010, under sections 501-541 of the Hiring Incentives to Restore Employment (“HIRE”) Act.[1]  FATCA was implemented with the aim of counteracting tax avoidance, and aims to improve tax compliance by imposing […]

Foreign Withholding Taxes

South African and multinational businesses operating in the larger African continent were elated by the introduction in 2011 of the section 6quin relief for withholding taxes suffered despite the treaty provisions preventing same. The elation, however, may be short lived! After offering much welcomed relief and promoting the gateway to Africa initiative for a mere […]

Advance Tax Rulings

There have been roughly 45 reported tax cases since January 2014. Of these SARS won twenty seven and taxpayers sixteen. Two of these cases were partial wins. As the charts below indicate, that means 60% of all cases taken to court in the last 19 months have been won by SARS. One may safely assume […]