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Transfer Pricing & International Tax
27 September 2013   (0 Comments - view/add)
Personal Tax Consequences For South African Executives On Foreign Boards »
    Author: Hanneke Farrand (ENS) and Chris van Wijngaarden (Taxand Netherlands) South African companies are...
08 August 2013   (0 Comments - view/add)
Erosion and Profit Shifting (BEPS) – OECD Action Plan »
Author: KPMG In February 2013, the Organisation for Economic Cooperation and Development (OECD) published a report, ...
07 August 2013   (0 Comments - view/add)
Malta and US conclude FATCA negotiations »
Author: CSB Group As recently reported, Malta and the US concluded negotiations relating to an Intergovernmental Agreem...
07 August 2013   (0 Comments - view/add)
Anti-tax Avoidance Exchange of Information Agreement With Gibraltar »
  Author: Peter Surtees & Andrew Wellsted On 11 July 2013 South Africa and Gibraltar signed an exchange of...
26 July 2013   (0 Comments - view/add)
Transfer Price Tax Risk ‘a priority’ For Companies »
Author: Amanda Visser (BusinessDay) Transfer pricing and the tax risk it presents to companies have become a major prior...
11 July 2013   (0 Comments - view/add)
Tax Controversy Some Controversial Issues »
  Author: Ernest Mazansky (Werksmans) Tax controversy has become a fairly common term to refer to what is, in r...
02 July 2013   (0 Comments - view/add)
Thin Capitalisation, Transfer Pricing and Cross Border Loans »
Author: Betsie Strydom (Bowman Gilfillan) Section 31 of the Income Tax Act, no 58 of 1962 ("the ITA”) was amended with e...
28 June 2013   (0 Comments - view/add)
South Africa as a base for Expansion Into Africa? »
Author: Jonathan Lang Africa is the cradle of humanity yet it is only now, in the early years of the twenty-first cent...
11 June 2013   (0 Comments - view/add)
South Africa’s tax treaty with the DRC provides a new avenue for international investment »
Author: PwC (PwC, Synopsis, Tax Today, May 2013) The tax treaty entered into between the Democratic Republic of Congo (...
10 June 2013   (0 Comments - view/add)
Fiscal residence – new Mauritius DTA provision modifies the test for companies »
Author: PwC (Synopsis, Tax Today, May 2013) Recent news articles on international tax have focused heavily on the use by...
07 June 2013   (0 Comments - view/add)
Mutual Assistance Provisions In Double Tax Agreement Between United Kingdom And South Africa »
Author: Danielle Botha In the recent case of Ben Nevis (Holdings) Limited & Metlika Trading Limited v The Commiss...
07 June 2013   (0 Comments - view/add)
SA is closing investment tax loopholes »
Author:  Brendan Peacock (Business Day live) South Africa signed a new double-taxation agreement with Mauritius on...
06 June 2013   (0 Comments - view/add)
Ben Nevis (Holdings) Limited and Metlika Trading Limited v Commissioners for HM Revenue & Customs »
Author:  Charl Geldenhuys Background to the case Ben Nevis (first appellant) and Metlika Trading Limited (MTL)...
31 May 2013   (0 Comments - view/add)
New Mauritian Tax Treaty »
Author: Heinrich Louw (Cliffe Dekker Hofmeyr) Mauritius has been a popular destination for international investors want...
29 May 2013   (0 Comments - view/add)
Tax treaty could see investors exit Mauritius »
Source: Ingé Lamprecht (Moneywebtax) Attempts to stop the ‘abuse' of a tax treaty between South Africa and Maur...
28 May 2013   (0 Comments - view/add)
New tax treaty between SA and Mauritius »
Source: SAPA (Moneywebtax) South Africa has signed a new tax treaty with Mauritius, accounting firm PriceWaterhouse Co...
24 May 2013   (0 Comments - view/add)
Amendments to the status overview of all DTAs and Protocols »
Source: SARS Legal & Policy The purpose of the agreements between the two tax administrations of two countries i...
23 May 2013   (0 Comments - view/add)
Transfer pricing rules for South African domestic intergroup transactions »
Source: Tarryn Spearman (Grant Thornton) The United Kingdom introduced transfer pricing rules nearly 50 years ago and...
22 May 2013   (0 Comments - view/add)
Gordhan: Top firms side-stepping tax »
Source: Fin 24 (SAPA) Cape Town - Too many big companies are shifting their profit centres to parts of the world where t...
13 May 2013   (0 Comments - view/add)
Unitary tax system to prevent transnational companies ‘dodging tax’ is probably unachievable »
Source: Louise Vosloo   (Deloitte) Johannesburg, 13 May 2013 - The implications of momentous changes to the glo...
03 May 2013   (0 Comments - view/add)
Guidance on how ‘arm’s length’ principle should be applied to financing of intra-group transactions »
Source:  Mark Badenhorst The South African Revenue Service (SARS) recently issued a new draft interpretation note...
02 May 2013   (0 Comments - view/add)
OECD’s Global Forum on Transfer Pricing releases Draft Handbook on Transfer Pricing Risk Assessment »
Source: OECD 30/04/2013 - In November 2011, the Steering Committee of the OECD Global Forum on Transfer Pricing undert...
02 May 2013   (0 Comments - view/add)
Concern about changes to transfer pricing legislation »
Source:  Ingé Lamprecht (Moneywebtax) A draft Interpretation Note on the cross-border pricing of goods and...
25 April 2013   (0 Comments - view/add)
Income tax notice raises new administrative risk for non-resident companies »
Source:  Johnathan Harley (Edward Nathan Sonnenbergs) Section 66 of the Income Tax Act No. 58 of 1962 ("the Act”)...
09 April 2013   (0 Comments - view/add)
SARS eyes global companies' tax structures »
Source: Chantelle Benjamin Multinationals based in SA - particularly in the mining, automotive, pharmaceutical and finan...
23 March 2013   (0 Comments - view/add)
Gateway to Africa »
By Arnaaz Camay (ENS Tax ENSight) Executive summary The SARB has approved approximately 1,000 investments into 36 A...
23 March 2013   (0 Comments - view/add)
Tax on foreign employment income likely to change »
By Jenny Klein (ENS Tax Ensight) Executive summary A recent announcement in the 2013 Budget proposed changes to th...
17 February 2013   (0 Comments - view/add)
Withholding tax on interest paid to foreign persons »
By Nicole Paulsen (DLA Cliffe Dekker Hofmeyr Tax Alert) Executive summary Currently, interest paid to foreign resid...
22 December 2012   (0 Comments - view/add)
Revised exit charge upon ceasing to be a resident in South Africa »
By Lavina Daya (ENS Tax Ensight) Executive summary Section 9H of the Income Tax Act was introduced with effect from 1...
18 December 2012   (0 Comments - view/add)
OECD consultation on the transfer pricing aspects of intangibles: summary of the Nov consultation »
By Caroline Silberztein and Melanie Schneider, Baker & McKenzie Executive summary This article summarises the Nov...
25 November 2012   (0 Comments - view/add)
Ordinarily resident - a taxing question »
By Johan van der Walt (DLA Cliffe Dekker Hofmeyr Tax Alert) Executive summary A natural person is regarded as a...
05 November 2012   (0 Comments - view/add)
The proposed amendments to the international headquarter company regime »
By Noxolo Ntombela (ENS Tax Ensight) Executive summary (SAIT Technical) The Draft Taxation Laws Amendment Bill propos...
02 November 2012   (0 Comments - view/add)
OECD, tax forum sign memo on transfer prices »
By Amanda Visser (Business Day) Executive summary (SAIT Technical) ATAF and the OECD signed a memorandum of co-...
26 October 2012   (0 Comments - view/add)
Double tax convention between SA and the Congo »
By SARS Legal & Policy The convention for the avoidance of double taxation and the prevention of fiscal evasion wit...
23 October 2012   (0 Comments - view/add)
Transfer pricing: judgment of the Supreme Court of Canada in the GlaxoSmithKline case »
By Emil Brincker (DLA Cliffe Dekker Hofmeyr Tax Alert) Executive summary (SAIT Technical) E mil Brincker discusses the...

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