The disclosure of specific corporate transactions and the resulting capital gains and losses has been significantly increased in terms of the new corporate tax returns (the ITR14's).The proposed transfer pricing guidelines in respect of excessive debt may force foreign lenders to SA companies to waive some or all of the debt owed to them and/or the SA company to convert the relevant debt to equity.
09:00am until 13:30pm
Glenhove Conference Centre
52 Glenhove Road
Johannesburg, Gauteng 2169
Online registration is closed.
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Preparing for a SARS Audit Presented By Ronel de Kock
Companies, shareholders and Capital Gains Tax
The disclosure of specific corporate transactions and the resulting capital gains and losses has been significantly increased in terms of the new corporate tax returns (the ITR14's).The proposed transfer pricing guidelines in respect of excessive debt may force foreign lenders to SA companies to waive some or all of the debt owed to them and/or the SA company to convert the relevant debt to equity. The tax efficiency of maintaining long term local debt will also have to be considered by companies due to proposed amendments seeking to deem the debt to be equity, interest payments in respect of the debt to be dividends and therefore non-deductible for tax purposes in the company's hands.
With buyers no longer willing to purchase companies and preferring instead to purchase selected business assets out of the company, all the tax consequences of the sale of a business versus the sale of shares must be clearly understood.
Companies being wound up, shareholder loans being waived or converted, disposal or replacement of business assets and companies distributing non-dividends to shareholders all have capital gains tax (CGT) consequences of which taxpayers must be aware.
Please join us as we address the CGT consequences for both the company and its shareholders of the issues listed above and many other corporate transactions including:
- New ITR14 CGT disclosure requirements
- Waiver of debt- effect on company as both debtor and creditor
- Conversion of debt to equity
- New transfer pricing guidelines
- Casual employees, reporting issues
- Sale of a business "lock stock and barrel”
- Disposal of allowance assets, CGT vs recoupments
- Replacement of allowance assets CGT vs recoupments
- New CGT exemption in respect of sale of foreign shares
Transactions between Companies and their shareholders:
- Shareholder liability for tax debts of company
- Distribution of a dividend in specie
- Distribution of non-dividends – repayment of contributed tax capital
- Share buybacks- listed and non-listed companies
- Liquidation distributions
- Share dealers vs share investors
- Waiver or conversion of shareholder loans
- Issue of shares as consideration for assets
- Share incentive schemes
WHO SHOULD ATTEND:
Corporate financiers and persons involved in financial planning and advisory services, Tax specialists, Practicing accountants and lawyers, In-house tax managers and advisors, Financial directors, managers and business owners
Di Seccombe (B Com, LLB, LLM (Taxation)
Di Seccoumbe is an admitted attourney with a Masters degree in taxation. Di started her tax career as a full time academic with the University of KwaZulu Natal before moving into practice. She is currently the National Head of Tax Training with Mazars and in this capacity trains and consults on Income Tax matters including, Corporate, Individual and International tax as well as VAT. Di, provides internal tax training for Mazars, and presents external tax seminars on a national basis, focusing on general as well as specialised tax topics. She still lectures part time for the National School of Accounting to assist up and coming CA's with passing the UNISA CTA (Hon) programme.
CPD: Attendance will secure 4.5 hours verifiable CPD points/units, incl. other professional bodies.
(SAICA, SAIPA, SAIBA, ACCA, FPI, ACIS, LSSA, FISA, ICB)
EVENT INVESTMENT: SAIT Members: R850.00
Affiliated Members R950.00