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2018 Budget Comments – International Tax

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South Africa has specific anti-tax avoidance legislation aimed at South African owned foreign companies. This so-called controlled foreign company tax legislation in essence aim to tax the notional taxable income of a foreign company in the hands of its South African shareholders.

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

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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.

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