South Africa introduced controlled foreign company (‘CFC’) rules when it adopted a residence-based tax system in 2001....
CFCs: The FBE exemption and outsourcing
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Corporate and business tax
Trusts: Conduit-pipe tax rules
The appellate division established the conduit-pipe principle in 1938 in Armstrong v CIR and confirmed it in subsequent cases....
Relief for SA tax residents who incur foreign taxes
South Africa has a residence-based income tax system. This means South African tax residents are subject to income tax on all...
Section 12BA: 125% allowance on renewable energy assets
Section 12B provides a 100% deduction for assets that a taxpayer uses in the generation of electricity from PV solar energy not...
Employee share schemes: South African tax considerations
Companies often set up employee share schemes that incentivise and align key staff members with the company’s broader...
Proposal to cushion Practice Note 31’s withdrawal
The National Treasury published the draft Taxation Laws Amendment Bill for the 2023 legislative cycle on 31 July 2023. It...