SECTION : SECTIONS 10(1)(k)(ii)(dd), 24B AND PARAGRAPH 64BOF THE EIGHTH SCHEDULE TO THE ACT
SUBJECT : INTERPOSING A CO-OPERATIVE BETWEEN A SOUTH AFRICAN HOLDING COMPANY AND ITS FOREIGN SUBSIDIARIES
This ruling deals with the income tax consequences arising from the saleof the shares held by a holding company in its foreign subsidiary to a Co-Operative to be incorporated, for an interest in that Co-Operative.
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.