TAX CONSULTING SA CONTRIBUTING AUTHORS
André Daniels
Head of Tax Controversy & Dispute Resolution
Admitted Attorney, LLB
Delano Abdoll
Legal Manager: Cross-Border Taxation
Admitted Attorney, BA (Law), LLB, LLM
Bronwin Human
Tax Attorney
Admitted Attorney, LLB
Micaela Paschini
Tax Attorney
Admitted Attorney, LLB
KIESWETTER MAKES NO EMPTY PROMISES NO ONE IS ABOVE THE LAW!
On 24 May 2023, the South African Revenue Service (SARS) released Interpretation Note 129 (IN129), which provides clarity on the interpretation and application of the phrase “maximum tax rate applicable to the taxpayer” in section 222(5) of the Tax Administration Act 28 of 2011 (“TAA”).
Read MoreOPPORTUNITY OR RISK: THE NEW SARS AIT TAX CLEARANCE STATUS PROCESS
On 24 April 2023, SARS announced the ‘new enhanced’ Tax Compliance Status (TCS) processes that were applicable with immediate effect. The changes that SARS announced included the discontinuation of the Tender TCS application, as well as the consolidation of the Foreign Investment Allowance…
AN OVERVIEW OF CHANGING SOUTH AFRICAN TAX RESIDENCY
Over time, the residence-based taxation system in South Africa has become more pivotal to internationally mobile persons, especially high-net-worth individuals and expatriates in general. In terms of this system, South African residents are taxed on their worldwide income and non residents are…
CASE LAW WRAP-UP
Commissioner for SARS v Coronation Investment Management SA (Pty) Ltd (1269/2021) [2023] ZASCA 10 (07 February 2023)
The issue before the Supreme Court of Appeal (SCA) in this matter was whether a controlled foreign company (CFC) constituted a foreign business establishment (FBE)…
BINDING RULINGS
Binding Private Ruling: BPR 387 Attribution of nett income to a public benefit organisation (09 December 2022)
This ruling determines the tax consequences of a public benefit organisation (PBO) holding a participatory interest in a controlled foreign company, which is a foreign…
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