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Interpretation Note 87: Headquarter companies

22 February 2016   (0 Comments)
Posted by: Author: SARS
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Author: SARS

This Note provides guidance and clarity on the interpretation and application of section 9I which deals with headquarter companies. Section 9I was initially inserted into the Act effective for years of assessment commencing on or after 1 January 2011. 

The Note also briefly discusses the provisions of the Act that provide special tax relief for headquarter companies, as well as the specific anti-avoidance rules that are designed to prevent misuse or abuse of those provisions. 

The Note does not discuss all of the sections which are applicable to headquarter companies. For example, the Note does not discuss "gross income” as defined in section 1(1) or section 11(a) which, although these sections do not specifically refer to headquarter companies, are applicable to headquarter companies.

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Section 240A of the Tax Administration Act, 2011 (as amended) requires that all tax practitioners register with a recognized controlling body before 1 July 2013. It is a criminal offense to not register with both a recognized controlling body and SARS.


The Act requires that a minimum academic and practical requirments be set to register with a controlling body. Click here for the minimum requirements of SAIT.

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