Tag: DTLAB

A workshop was recently hosted by National Treasury on the proposed changes in the draft Taxation Laws Amendment Bill, 2017 (TLAB) on converting debt to equity. These proposed amendments in the draft TLAB are in sections 19, new sections 19A and 19B, and paragraph 12A of the Eighth Schedule in the Income Tax Act 58 of 1962.

In the 2017 Budget, delivered by the Minister of Finance, it was proposed that additional measures will be considered to circumvent transactions where investors choose to realise their share investments by means of having the shares they hold in a company bought back and characterised as a dividend, while being paid for by means of a new investor subscribing for shares in the same company. This followed on the back of a similar announcement in 2016, whereafter no two specific countermeasures were introduced.

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.