All Articles
Place of effective management: SARS’ views
Place of effective management (‘POEM’) is critical in determining the South African tax residence of persons other than natural persons. SARS recently published Issue 3 of Interpretation Note 6 (‘IN6’), which deals with POEM. This article considers the continued...
Input tax: Holding companies
Vendors may deduct input tax on goods or services acquired for purposes of making taxable supplies in the course of furtherance of their enterprise. This article considers a recent tax court judgment (case 1922) that dealt with input tax deducted by a...
Income tax verification: Assessed losses
SARS did away with the IT14 supplementary declaration for companies (IT14SD) in September 2022. It replaced that declaration with a letter that requests supporting documents based on the reason for the verification. This article considers a recurring request to...
Budget 2023: Tax proposals
The Budget 2023 sets out the National Treasury’s proposals for tax amendments in the 2023 legislative cycle. This article briefly considers a selection of proposals. Energy incentives The Budget Review proposes two incentives to encourage private energy...
Intra-group loans: Tax complexities
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,...
The MLI comes into effect for South Africa
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...
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