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International News
11 April 2017   (0 Comments - view/add)
Dividends declared to non-resident companies and the “most favoured nation” clause in tax treaties »
Author: Jerome Brink (CDH) It was announced by the Minister of Finance in the 2017 Budget that the dividends tax r...
04 October 2016   (0 Comments - view/add)
Double Non-taxation of Hybrid Debt Instruments Issued by Non-residents »
Author: Esther van Schalkwyk (BDO SA) National Treasury indicated its intention to address double non-taxation, if a...
04 October 2016   (0 Comments - view/add)
OECD branches out – proposing BEPS Action 2 recommendations to tackle branch mismatch structures »
Author: Lisa Brunton (Cliffe Dekker Hofmeyr) On 22 August 2016 the OECD released Public Discussion Draft: BEPS Acti...
13 September 2016   (0 Comments - view/add)
BEPS involving interest in the banking and insurance sectors »
Author: Lisa Brunton (Cliffe Dekker Hofmeyr) In October 2015, the OECD BEPS Action 4 Report on Limiting Base Erosion Inv...
15 August 2016   (0 Comments - view/add)
Off down the rabbit-hole in pursuit of the OECD/G20 BEPS project developments in a world run mad »
Author: Lisa Brunton (Cliffe Dekker Hofmeyr) The European migrant crisis has reached catastrophic proportions. In 2015 m...
22 June 2016   (0 Comments - view/add)
Controlled foreign companies – sharing substance »
Author: PwC South Africa SARS recently called into question the right of resident companies to claim exemption from imp...
15 June 2016   (0 Comments - view/add)
OECD Request for Input on the development of a multilateral instrument to implement tax treaty BEPS »
Author: Elsabe Strydom (ENSafrica) The Organisation for Economic Co-operation and Development ("OECD”)/G20 Base Erosion...
06 June 2016   (0 Comments - view/add)
SARS rules again on the capitalisation of loan accounts »
Author: Ben Strauss (Cliffe Dekker Hofmeyr) The South African Revenue Service (SARS) has now issued a number of rulings...
01 June 2016   (0 Comments - view/add)
UK Deemed Domicile Rules – Is Malta a Viable Alternative? »
Author: Pierre Buttigieg (CSB Group) What changed? The UK has announced significant changes to the basis of taxation...
30 May 2016   (0 Comments - view/add)
Automatic Exchange of Information – FATCA, CRS, UK CDOT and other ominous acronyms »
Author: Lisa Brunton (Cliffe Dekker Hofmeyr) By now, we’re all familiar with the term, Automatic Exchange of Information...
19 May 2016   (0 Comments - view/add)
Pension funds and BEPS »
Author: Magda Snyckers (ENSafrica) Is the current international tax focus on base erosion and profit shifting ("BEPS”) r...
19 May 2016   (0 Comments - view/add)
Can a controlled foreign company have more than one foreign business establishment? »
Authors: Carmen Gers and Chris de Bruyn (ENSafrica) In terms of the South African controlled foreign company ("CFC") leg...
19 May 2016   (0 Comments - view/add)
Update on the taxation of South African dividends to the Netherlands »
Authors: Stephan Spamer and Howmera Parak (ENSafrica) In 2014 and 2015, ENSafrica published two articles on the "most fa...
09 May 2016   (0 Comments - view/add)
Interpreting the language in a double taxation agreement »
Author: PwC South  Africa With the steady erosion of international boundaries in commerce, South African resident...
03 May 2016   (0 Comments - view/add)
Electronic format for the exchange of CbC reports released »
Author: Arnaaz Camay (ENSafrica) On 22 March 2016, the Organisation for Economic Development and Co-operation ("OECD”) r...
03 May 2016   (0 Comments - view/add)
The evolution of the “Foreign Partnership” definition in South Africa »
Author: Refilwe Mashale (ENSafrica) In South Africa, the determination of whether a foreign entity is a company or partn...
03 May 2016   (0 Comments - view/add)
Draft regulations for the implementation of Country-by-Country reporting published in South Africa »
Author: Arnaaz Camay (ENSafrica) The South African Revenue Service ("SARS”) is, in accordance with section 3(2)(j) of th...
25 January 2016   (0 Comments - view/add)
Two new double tax agreements »
Author: PwC South Africa Readers will note from SARS Watch that a new double taxation agreement between South Africa an...
03 November 2015   (0 Comments - view/add)
Retroactive application of a double tax agreement »
Author: PwC South Africa On 16 October 2015, a Protocol amending the double tax agreement (DTA) between South Africa an...
19 October 2015   (0 Comments - view/add)
Merger of controlled foreign companies »
Author: Heinrich Louw (Cliffe Dekker Hofmeyr) A South African incorporated and resident company (Applicant) had two subs...
13 October 2015   (0 Comments - view/add)
Large business tax strategy behaviour – a UK research study »
Author: PwC South Africa On 22 July 2015, Her Majesty’s Revenue and Customs (HMRC – the United Kingdom’s counterpart to...
21 September 2015   (0 Comments - view/add)
New tax changes mean new tax schemes »
Author: BDO South Africa Consumers and businesses by now have had a few months to assess the impact of tax changes indic...
15 September 2015   (0 Comments - view/add)
Foreign Tax Recovery Assistance »
Author: SARS A new page was created to provide the two forms that are used between the Competent Authorities of Foreign...
15 September 2015   (0 Comments - view/add)
Tax treatment of awards received from foreign trusts by South African beneficiaries »
Author: Dr Beric Croome Where a South African tax resident beneficiary receives an award from a foreign trust, it is imp...
14 September 2015   (0 Comments - view/add)
Energy sector license and consent charges: Capital or revenue? »
Author: Ben Strauss (Cliffe Dekker Hofmeyr) Recently two interesting cases were reported in New Zealand and Australia. T...
02 September 2015   (0 Comments - view/add)
Foreign entities deriving income from South Africa must register as taxpayers »
Author: Douglas Gaul (Grant Thornton Johannesburg) It has long been a requirement that a non-resident company, trus...
02 September 2015   (0 Comments - view/add)
Status Overview of all Tax Information Exchange Agreements »
Author: SARS Grenada TIEA was ratified in South Africa (27 August 2015). Please  click here  to view.
02 September 2015   (0 Comments - view/add)
Protocol amending Cyprus-South Africa double tax agreement signed »
Author: Philippos Aristotelous (International Law Office) Introduction On April 1 2015 Cyprus and South Africa signed...
01 September 2015   (0 Comments - view/add)
A review of section 6quin »
Author: Pieter van der Zwan (NWU) Pieter van der Zwan revisits the economic reasons for the introduction of section 6qu...
20 August 2015   (0 Comments - view/add)
FATCA legislation to impact SA financial services sector »
Author: CBN South African companies who do direct and indirect business with US organisations, whether in South Africa,...
04 August 2015   (0 Comments - view/add)
The Global Forum releases new compliance ratings on tax transparency »
Author: OECD The  Global Forum on Transparency and Exchange of Information for Tax Purposes  published new pee...
28 July 2015   (0 Comments - view/add)
Amendments to CFC Diversionary Income Rules »
Authors: Leani Nortje and Nola Brown (Webber Wentzel) Section 9D currently provides for diversionary income rules which...
27 July 2015   (0 Comments - view/add)
Tax/Exchange Control Newsflash »
Authors: Phillip Lourens, Natalie Napier and Jackie Peart (Hogan Lovells) On 9 J...
27 July 2015   (0 Comments - view/add)
Third party returns – exchange of information in accordance with international tax standards »
Authors: Gigi Nyanin and Nicole Paulsen (DLA Cliffe Dekker Hofmeyr) In order to provide the necessary legislative amendm...
27 July 2015   (0 Comments - view/add)
Withdrawal of foreign tax credits for South African-sourced income »
Author: BDO South Africa The 2015 Budget announced by Finance Minister Nene included a number of measures to bolster tax...

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