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International News
08 December 2017   (0 Comments - view/add)
Travelling abroad and travel allowances – what you can and can’t do »
Author: Louis Botha (CDH) Europe, America, Asia – for South Africans fortunate enough to do so, travelling abroad is...
07 November 2017   (0 Comments - view/add)
Amendment in respect of foreign employment income exemption »
Author: Nandipha Mzizi and Louis Botha, (cliffedekkerhofmeyr) Alongside the 2017 Medium Term Budget Policy Statements,...
02 October 2017   (0 Comments - view/add)
South Africans working and living abroad – the excon considerations »
Author: Louis Botha (CDH) Despite some people not being aware of it, an important issue to consider in this regard...
20 September 2017   (0 Comments - view/add)
What are the tax and exchange control implications of Bitcoin? »
Author: Robert Gad, Nicolette Smit, Megan McCormack, Jo-Paula Roman (ENSafrica) With virtual currencies such as Bitc...
20 September 2017   (0 Comments - view/add)
Unintended consequences of the new CFC rules »
Author: Judith Becker (ENSafrica) In the 2017 South African Budget speech, the Minister of Finance raised government...
12 September 2017   (0 Comments - view/add)
The BEPS effect - Has Lord Tomlin’s famous 1936 dictum become obsolete? »
Author: Candice Gibson (CDH) The last two centuries have seen courts handing down judgments wherein the House of Lord...
28 August 2017   (0 Comments - view/add)
"There is a crack, a crack in everything. That’s how the light gets in." »
Author: Lisa Brunton (CDH) In June 2017, during a ceremony hosted in Paris by the Organisation for Economic Co-operat...
16 August 2017   (0 Comments - view/add)
Retrospective country-by-country reporting and transfer pricing documentation requirements »
Author: Robyn Kantor (ENSafrica) South Africans who think that their tax burden is going to decrease because country...
16 August 2017   (0 Comments - view/add)
South Africans working abroad – proposed removal of tax exemption »
Author: Jenny Klein (ENSafrica) On 19 July 2017, the South African National Treasury released the 2017 Draft Taxatio...
23 July 2017   (0 Comments - view/add)
Timing raises new questions over treaty with Gulf tax haven »
Author: Author: Graeme Hosken (Talk of the Town)   The Gupta family sought advice on how to move ten...
20 July 2017   (0 Comments - view/add)
BEPS Action 8 on Hard-to-Value Intangibles »
Authors: Lavina Daya and Ivette du Toit (ENSafrica) One of the main action items identified by South Africa’s Natio...
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...

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