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Transfer pricing implementation and enforcement – a source for taxes?

Transfer pricing relates to the transfer of goods or services between members of a multinational group which are tax residents in different countries. Instead of increasing existing taxes or levying new taxes, a way to tackle the looming budget deficit may be to properly implement transfer pricing rules and to ensure appropriate enforcement by the South African Revenue Service (SARS) of such rules.

New SA transfer pricing rules – can we expect additional collections?

Transfer Pricing compliance requirements in South Africa have been significantly tightened and a modern transfer pricing system, including electronic transfer pricing return submission, has been put in place.

Dormant company debt a tax headache?

Corporates 'can' acknowledge that winding up a dormant company within their South African group of companies can result in a tax headache.

Vital VAT rate increase considerations!

While the necessary legislative provisions to give effect to the proposed increase are still to be adopted by Parliament, one can accept that the Minister's proposal to increase VAT from 1 April 2018 will be implemented. A number of important issues need to be considered to ensure a seamless transition.

How will ETI and YES work together?

The two programmes, the Employment Tax Incentive (ETI) created by and falling under SARS, and the Youth Empowerment Service (YES) by the Department of Trade and Industry, are designed to work together and to compliment one-another.

South African tax treatment of global citizens

Statistics South Africa (StatSA) released the Community Survey in 2016 noting that a total of 94,760 South Africans have emigrated between 2006 and 2016. A more recent study performed by the Pew Research Centre in February 2018 notes that 900,000 people born in South Africa were living abroad for one year or longer. The top three destinations being United Kingdom, Australia and United States.

TAX JUDGEMENT | When SARS prescription starts

In the recent case of CSARS v Char Trade, the Supreme Court of Appeal (SCA) that prescription begins to run against CSARS when a return for secondary tax on companies (STC) is submitted to SARS by a taxpayer.

SOUTH AFRICA’S 2017 BUDGET

Minister Pravin Gordhan and his team at National Treasury should be praised for striking the correct fiscal balance in this year’s budget. Gordhan understands...

Double tax danger for foreign companies held by foreign trusts or...

The much-anticipated Draft Taxation Laws Amendment Bill came out on 19 July 2017. From an international tax perspective, issues of interest include the proposed changes and additions to the Controlled Foreign Company (CFC) rules. Of concern is the possibility that double tax might be payable in certain cases.

IP regulations impact tax & exchange controls

Multinationals in high-tax jurisdictions will now benefit from relaxed IP regulations. The 2017 Budget announced that the regulatory framework regarding cross-border intellectual property transactions is to be relaxed, for both tax and exchange control purposes.
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