South Africa: Tax consequences of debt reduction transactions
South Africa’s Taxation Laws Amendment Act, 2012, includes provisions that revise the tax treatment of debt reduction transactions entered into on or after 1 January 2013. Since the objective of the new tax reduction rules is to make it easier
See MoreSaudi Arabia – Procedures to claim reduced withholding tax rates under tax treaties
The tax authority of Saudi Arabia has issued guidance- Circular No. 5068/16/1434 about the procedure of claiming reduced withholding tax rates under double tax treaty conventions of Saudi Arabia. According to the guidance an entity of Saudi Arabia
See MoreSouth Africa: Private ruling on capital gains tax in South Africa
A ruling has been issued that may help taxpayers to determine the tax position in a situation where a loan has been cancelled. On 13 August 2013, the South African Revenue Service (SARS) issued a binding private ruling dealing with the question as
See MoreSARS Updates ATR Application Process
The process of application for a tax ruling is sometimes seen by taxpayers as daunting and they may prefer not to embark on the procedure even though it can provide them with some certainty as to the outcome of planned transactions. There is
See MoreTanzania – Requirements for business licenses
Recently Tanzania’s Ministry of Industry and Trade issued details of the procedures necessary for businesses to register for or renew their business licenses on or before 31st December 2013. In July 2013 the Permanent Secretary in the Ministry of
See MoreMalta and Turkey DTA entered into force
The Income Tax Treaty (2011) between Malta and Turkey for the avoidance of double taxation entered into force on 13 June 2013. The treaty generally applies from 1 January 2014. OECD Model Tax Treaty is broadly followed in this
See MoreProtocol to DTA between India and Morocco signed
India and Morocco have signed a protocol to their Double Taxation Avoidance Convention. This protocol will bring the information exchange provisions under the treaty into line with international standards. There is an increasing international
See MoreSouth Africa: Revamped Shipping Tax Regime
The South African Revenue Service (SARS) released the draft Taxation Laws Amendment Bill, 2013 on July 14, 2013. The proposed effective date of the legislation is from January 1, 2014. The legislation introduces a revised tax regime for shipping
See MoreOman: VAT could be introduced by 2016
For implementing a value added tax (VAT), the Oman government is considering a framework. This would be generally in line with guidance from the Gulf Cooperation Council, an organization of which Oman is a member. VAT system could be implemented in
See MoreKuwait and Hong Kong: DTA entered into force
The Hong Kong Special Administrative Region and Kuwait signed an Income Tax Treaty in May 2010. In a press release it has been announced that the treaty came into force on July 24 after completion of ratification procedures on both sides. The
See MoreDTA between Australia and Mauritius entered into force
The Double Tax Agreement (DTA) between Australia and Mauritius entered into force on 31 May 2013. The treaty will be relevant to persons who are residents of one or both of the Contracting States. For the purposes of the Agreement a person is not a
See MoreTurkey: New e-invoice obligations
The Turkish VAT authorities have introduced a mandatory e-invoice system for all companies and individuals from September 1, 2013. An e-invoicing system was first introduced in 2010 and this is now being made compulsory for certain taxpayers groups.
See MoreNigeria: Tax implications for adopting IFRS
Under the IFRS regime, the circular proposes clarifications as to how specific assets, expenses, and income will be acted for tax motives. It also highlights the position of Nigerian tax authority on other issues, like the tax treatment of costing
See MoreSouth Africa: proposal to limit interest deductions involving cross-border related party debt
The South African National Treasury released proposed legislation, on 4 July 2013, that seeks to limit interest deductions relating to debt owed by South African subsidiaries to foreign parent companies. The purpose of the proposed legislation is to
See MoreSouth Africa: E-Filing for Excise Duties
South Africa published Government Notice R.487 on 11 July 2013 providing for all excise accounts to be submitted on e-Filing with immediate effect. Manual submissions will only be accepted for a period of three months from 11 July 2013. After the
See MoreSouth Africa Consults On Budget Tax Reform Bill
On 4 July 2013 the National Treasury published the 2013 draft Taxation Laws Amendment Bill (TLAB) and the Tax Administration Laws Amendment Bill for public comment. The draft legislation would give effect to most of the tax proposals announced in
See MoreTreaty between Kuwait and Slovenia enters into force
The Income and Capital Tax Treaty between Kuwait and Slovenia entered into force on 17 May 2013. The treaty generally applies from 1 January 2014. Under the Treaty, the definition of a permanent establishment includes a situation where substantial
See MoreTanzania: Tax proposals for 2013 budget
The Tanzanian Budget for 2013 was presented to the National Assembly by the Minister of Finance and key changes made by the Budget proposals are summarized below: Reduction of the minimum tax rate for individuals from 14% to 13%. Abolition of a
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