by Pieter van der Zwan | Feb 9, 2023 | Corporate and business tax
Interpretation note on intra-group loans SARS recently published Interpretation Note 127 (‘IN127’). It mainly deals with applying the arm’s length principle to intra-group loans, as the transfer pricing rules require. This complex area requires consideration of,...
by Pieter van der Zwan | Jan 11, 2023 | Corporate and business tax, General tax matters
Action 15 of the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (‘BEPS’) required the development of a multilateral instrument (‘MLI’). This instrument allows countries to modify existing bilateral tax treaties synchronously and efficiently to...
by Pieter van der Zwan | Nov 9, 2022 | Amendments, Corporate and business tax
The National Treasury published the Taxation Laws Amendment Bill for 2022 on 26 October 2022. Amongst others, this bill includes an amendment that affects returns of capital. This is the outcome of a process that started in 2021. Principles of returns of capital When...
by Pieter van der Zwan | Oct 26, 2022 | General tax matters
The first step for an aggrieved taxpayer to dispute a tax assessment is generally to lodge an objection in terms of section 104 of the Tax Administration Act (the TAA). In this article, I consider The Commissioner for the South African Revenue Service v Airports...
by Pieter van der Zwan | Sep 21, 2022 | Corporate and business tax, Value Added Tax
There are many costs to raise funding for a business, whether debt or equity capital. These include raising fees, initiation fees, facility fees and charges relating to structuring the transaction, to mention a few. In this article, I consider a recent case that dealt...
