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The finer details of asset-for-share transactions
The Income Tax Act (Act) allows for roll-over relief in certain circumstances where assets are contributed to a company in exchange for shares in the company. These transactions are referred to as asset-for-share transactions and the relief afforded is contained in...
The fine line between dividends and income
Dividends are generally not subject to normal tax in the hands of the recipient. The profits from which such dividends have been paid would already have been taxed in the company where it arose. Depending on the recipient, the dividend may be subject to an additional...
Tax issues: socio-economic and development expenditure
South African businesses play an integral role in socio-economic upliftment and development of communities, in particular those communities that were disadvantaged by the previous political dispensation. This role may be fulfilled on a voluntary basis, but is often...
Dividend-stripping and share buy-back transactions
Dividends paid by one South African company to another have been exempt from both normal tax and dividends tax since April 2012 when dividends tax came into effect. This has created opportunities for taxpayers to structure transactions where shares are disposed of in...
Revised debt restructuring tax rules
The Taxation Laws Amendment Bill (TLAB) that was published by the National Treasury on 25 October 2018 contains a revised set of rules that apply to debt restructuring transactions. This article provides a high level overview of some of the changes that will take...
Disputing understatement penalties
The Tax Administration Act (TAA) requires SARS to impose an understatement penalty (USP) in the event of an understatement. A recent tax court case (IT14247) dealt with the question whether SARS was entitled to impose such penalties in circumstances where a taxpayer...
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