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International News
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...
20 July 2015   (0 Comments - view/add)
Swiss banks agree US tax evasion deal with Justice Department »
Author: BBC News Business Two more Swiss banks have agreed deals with the US Justice Department over tax evasion by Ame...
13 July 2015   (0 Comments - view/add)
Awards from foreign trusts »
Author: Heinrich Louw (DLA Cliffe Dekker Hofmeyr) The South African Revenue Service (SARS) published Binding Private Rul...
03 July 2015   (0 Comments - view/add)
BPR 196: Employees' Tax: Monthly pension benefits in respect of foreign services rendered »
Author: SARS This ruling deals with whether or not a pension fund will be liable to deduct employees’ tax from the month...
03 July 2015   (0 Comments - view/add)
BPR 197: Exemption from donations tax and net value of an estate »
Author: SARS This ruling deals with the donations tax consequences arising from the onward or subsequent donation of fun...
24 June 2015   (0 Comments - view/add)
Diverted profits tax - a real concern for Global Business »
Authors: Robert Aziz, Nick Udal, Malcolm Joy and Tim Ferris (BDO LLP) The UK's new diverted pro...
24 June 2015   (0 Comments - view/add)
OECD Work On Restricting The Abuse Of Double Taxation Treaties »
Author: BDO LLP In September 2014, the OECD released proposed changes to its model tax convention to prevent abuse of tr...
21 April 2015   (0 Comments - view/add)
Release of a discussion draft on BEPS Action 11 (Improving the analysis of BEPS) »
Author: OECD Public Comments are invited on a  discussion draft  which deals with Action 11 (Improving the ana...
10 April 2015   (0 Comments - view/add)
OECD: Federal-State relations in Australia »
Authors: Vassiliki Koutsogeorgopulou and Annamaria Tuske (OECD) Australia’s inter-governmental  fisc...
10 April 2015   (0 Comments - view/add)
OECD: Improving taxes and transfers in Australia »
Author: Philip Hemmings and Annamaria Tuske (OECD) Getting tax and transfer systems to efficiently deliver suf...
10 April 2015   (0 Comments - view/add)
OECD Tax Database »
Author: OECD The OECD tax database provides comparative information on a range of tax statistics - tax revenues, persona...

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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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