The South African Revenue Service (SARS) on February 12 2015 released draft guidance on tax incentives for headquarters companies, designed to encourage MNEs to local operations in South Africa as a gateway to African investment.
The guide briefly discusses the provisions of the Act that provide special tax relief for headquarters companies, as well as the specific anti-avoidance rules that are designed to prevent misuse or abuse of those provisions.
The law, effective for tax years after January 1, 2011, provides special tax breaks for qualifying companies, including relief from income tax, capital gains tax, and dividend tax, as well as relaxed transfer pricing rules.