Tax amendments introduced by the 2012 Taxation Laws Amendment Bill, including court cases reported and SARS rulings issued, introduced material changes to the tax regime affecting corporate and large business centre ('LBC') taxpayers
This 2013 Corporate Tax Update will cover all critical amendments to ensure that corporate and LBC taxpayers update their tax strategy, mitigate their tax risks
and ensure that functions are performed adequately.
Significant changes introduced include:
- Amendments to the Corporate Rules
- Debt pushdowns
- Interest deductions on borrowings used for the acquisition of shares
- Anti-avoidance provisions: hybrid equity instruments
- Real Estate Investment Trusts
- Market to market taxation of financial instruments in the banking and insurance sectors.
Specific topics to be covered:
- Developments in policy and tax law on anti-avoidance
- New penalty regime and other significant matters introduced by the Tax Administration Act, 2011
- Fringe benefits, variable remuneration and medical credits
- Hybrid equity instruments
- Headquarter companies' taxation
- Rebates on foreign taxes
- Withholding taxes: interest and royalties
- Change of residence
- Extension of Corporate Rules
- Tax treatment of Government Incentives
- Taxation of Real Estate Investment Trusts
- Limitation of interest deductions
Recent case law developments
Who should attend
Tax specialists, corporate tax directors and managers, tax lawyers, financial directors and managers as well as chartered accountants.
Peter Dachs - BA, LLB (cum laude), LLM, HDip Tax
Peter Dachs is a director at ENS (Edward Nathan Sonnenbergs) and has 21 years experience. He currently practices as an attorney in the tax department. He specialises in financial services, mergers and acquisitions and international tax. In particular he advises South African corporates and financial institutions on their domestic tax issues in relation to, amongst others, group re-organisations, financing and mergers and acquisitions. He also provides advice to South African multi-nationals in respect of the South African tax consequences arising from their offshore investments. The scope of advice includes profit extraction mechanisms, controlled foreign company planning and transfer pricing advice. In addition, he advises multi-nationals investing into South Africa in respect of appropriate investment strategies.
He has acted for South African and foreign corporates, South African and foreign banks and South African financial institutions (such as insurance companies). He also provides advice to high net worth individuals in respect of their investments, in particular the tax consequences of South African and offshore trusts.
Peter's practice experience also includes advising on exchange control issues in respect of both investments into and out of South Africa.
He jointly leads the firm's tax department with Bernard du Plessis. He is an editor of the Taxpayer Magazine including Meyorowitz on Income Tax. He has co-authored Silke on International Tax and is co-authoring Broomberg's Tax Strategy. He has held lectures on tax at the University of Cape Town, the University of Stellenbosch and the University of the Witwatersrand.
Beric Croome - BComm, CTA, B Proc, LLB, Higher Diploma in Tax Law (cum laude), Doctor of Philosophy (Commercial Law)
Beric Croome is an executive at ENS (Edward Nathan Sonnenbergs) and has over 24 years experience in tax. He specialises in corporate tax, employee incentives and benefits, employment tax, personal tax, retail and share incentive schemes.
He has acted for clients in their dealings with the South African Revenue Service (SARS), and has advised clients on taxpayer's rights, income tax, Value-Added Tax (VAT), Pay As You Earn (PAYE) and other fiscal statutes as well as the tax consequences of foreign investments.
He is the author and co- author of two books. The first book, "Taxpayers' Rights in South Africa", aims to evaluate how the powers of the South African Revenue Service (SARS) functions in relation to taxpayers rights. The second book, "Tax Administration" was written together with Professor Lynette Olivier. Beric is a member of the editorial panel of The South African Institute of Chartered Accountants' (SAICA) tax publication, Integritax. He also sits on the technical committee of the South African Institute of Tax Practitioners. He has spoken at both international and local conferences, including providing the key-note address at a graduation ceremony at the University of the Witwatersrand's Faculty of Commerce Law and Management.
Beric was a nominee for the University of the Witwatersrand Convocation Honour Award for his contribution to commerce and industry.
Robert Gad - BA, LLB, LLM, Post Graduate Diploma in Tax
Robert Gad is a director at ENS (Edward Nathan Sonnenbergs) and has 27 years experience. He currently practices as an attorney in the tax department and specialises in corporate tax, share incentive schemes, mergers and acquisitions, private client, VAT and tax litigation.
Robert is the co-author of a chapter in the book Getting the Deal Through: Tax on Inbound Investment in 2008 and 2009. He is Deputy Chairman of the South African Law Society's Committee on Exchange Control and Tax Matters.
Attendance will secure 4 hours verifiable CPD points/units, incl. with professional bodies SAICA, SAIPA, SAIBA, ACCA, FPI, ACIS, LSSA, FISA
SAIT Members: Free
ENS clients: Free Non-Members: R2 190.00