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World: Global Legal Insights - Corporate Tax

25 July 2014   (0 Comments)
Posted by: Author: Alan Keep
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Authors: Alan Keep and Mogola Makola (Bowman Gilfillan Inc.)

The corporate tax work of the past year has been mixed. There have been a number of corporate restructuring transactions, refinancing of debt push down transactions and a number of transactions involving share repurchases by companies as a means of enabling shareholders to exit companies. We have also seen an increasing number of enquiries by the South African Revenue Service ("SARS") based on the General Anti-Avoidance Rules. As stated above, there have also been a number of transactions involving share repurchases by companies as a means of enabling shareholders to exit companies. The share repurchase became a favoured way of exiting a company, particularly for South African resident company shareholders, where the proceeds of the share repurchase were treated as a dividend for the purposes of the Income Tax Act ("ITA").

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This article first appeared on bowman.co.za.


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