by Pieter van der Zwan | Sep 15, 2024 | Corporate and business tax
There have been few transfer pricing-related tax cases in South Africa. They mainly dealt with technicalities of section 31 of the Income Tax Act (‘the ITA’). However, a recent tax court case deals with applying the arm’s length principle, which is at the heart of...
by Pieter van der Zwan | Jun 28, 2024 | Corporate and business tax
South Africa introduced controlled foreign company (‘CFC’) rules when it adopted a residence-based tax system in 2001. These rules target passive or mobile income that escapes South African tax by accruing or diverting it to offshore companies controlled by...
by Pieter van der Zwan | Mar 14, 2024 | Value Added Tax
Registered VAT vendors can deduct input tax in respect of goods and services supplied to them. However, they may only deduct such input tax only if, or to the extent, that they acquired goods or services to use, consume or supply in the course of making taxable...
by Pieter van der Zwan | Feb 8, 2024 | Corporate and business tax, General tax matters, Individuals and wealth planning
The appellate division established the conduit-pipe principle in 1938 in Armstrong v CIR and confirmed it in subsequent cases. If this principle applies, the beneficiary entitled to the trust income is liable for tax on the income. Section 25B of the Income Tax Act,...
by Pieter van der Zwan | Feb 1, 2024 | Corporate and business tax, General tax matters
South Africa has a residence-based income tax system. This means South African tax residents are subject to income tax on all their income, irrespective of the source. Both South Africa and another country, therefore, often tax income arising abroad. The Income Tax...
