South Africa: Dutch court ruled on exemption of withholding tax on dividend payments
On 17 August 2017, a Dutch lower court ruled that dividend payments from the Netherlands to South African corporate entities with 10% or more ownership in the company are not subject to Dutch dividend withholding tax. The case involved a 2013
See MoreSouth Africa: DTA with Cameroon enters into force
The double tax agreement between South Africa and Cameroon entered into force on 13 July 2017, according to a SARS notification published on 1 September 2017. The treaty was signed on 15 February 2015. Under the agreement the withholding tax rate on
See MoreSouth Africa: SARS releases draft taxation amendment bill for public comment
The National Treasury and the South African Revenue Service (SARS) published on 19 July 2017 for public comment the 2017 Draft Taxation Laws Amendment Bill (TLAB) and the 2017 Draft Tax Administration Laws Amendment Bill (TALAB). Together with the
See MoreSouth Africa-Turkey amending protocol enters into force
The amending protocol to the double tax agreement between South Africa and Turkey entered into force on 15 July 2017, according to a SARS notification published on 28 July 2017. The protocol was signed at Pretoria on 3 March 2005 to amend the
See MoreSouth Africa: SARS issues country by country reporting, master file and local file guidance
On 23 June 2017, the South African Revenue Service (SARS) released an external Business Requirements Specification (BRS) document concerning Country-by-Country and Financial Data reporting. The document contains the draft public notice requiring the
See MoreSouth Africa issues guidance on VAT on non-executive director fees
The South African Revenue Service issued guidance on the value added tax (VAT) treatment of fees paid to non-executive directors. On 10 February 2017, SARS issued binding general ruling (BGR) 41 which confirms that a non-executive director (NED) who
See MoreSouth Africa and U.S. sign an agreement on the exchange of country-by-country reports
The competent authorities of South Africa and the U.S. have concluded an arrangement on the exchange of Country-by-Country Reports. On June 5, 2017 the South African Revenue Service (SARS) released the text of the arrangement. According to SARS the
See MoreSouth Africa: SARS publishes draft notice on BEPS related compliance
On June 1, 2017, the South African Revenue Service (“SARS”) published a draft public notice requiring the submission of country-by-country (“CbC”) reports, a master file and a local file by groups with turnover above a specified
See MoreSouth Africa: SARS introduces improvements to the dispute management process
On 15 May 2017 the South African Revenue Service (SARS) introduced important changes and improvements to its current dispute management process as part of its ongoing commitment to delivering a better service to taxpayers. The following changes
See MoreSouth Africa-Grenada TIEA enters into force
The Tax Information Exchange Agreement (TIEA) between South Africa and Grenada entered into force on 10 March 2017, following publication in the Official Gazette of the Republic of South Africa on 13 April 2017. The agreement provides for the
See MoreHong Kong: Government signed AEOI agreement with Portugal and South Africa
The government of Hong Kong has signed agreements with Portugal and South Africa for conducting automatic exchange of financial account information in tax matters (AEOI). A Government spokesman said on 03 April 2017 that they have been seeking to
See MoreSouth Africa: SARS issues ruling on MFN clause in a treaty with Sweden
On 1 March 2017, the South African Revenue (SARS) issued a private binding ruling no. BPR 267 regarding dividends tax and the ‘most favoured nation’ clause in a tax treaty concluded with Sweden. The ruling determines whether dividends tax must
See MoreSouth Africa: National Treasury consults on sugar tax amendments
Proposed changes to the tax on sugar-sweetened beverages (SSBs) were introduced in the recently announced 2017-18 Budget. The South African National Treasury has issued a list of questions and answers on the changes to the proposed tax. The National
See MoreSouth Africa: Government increased the rate of dividends withholding tax (DWT) from 15% to 20%
The 2017 Budget Speech delivered by Minister Gordhan on 22 February 2017 increased the rate of Dividends Withholding Tax (DWT) from 15% to 20%. To reduce the difference between the combined statutory tax rate on dividends and the top marginal
See MoreSouth Africa: Transfer pricing proposals in 2017 budget
The Finance Minister of South Africa on 22 February 2017 delivered the budget speech to Parliament. In his speech the Minister mentioned the government’s plan for implementing a statutory transfer pricing regime in South Africa. The government
See MoreSouth Africa: Finance Minister presents the Budget for 2017-2018
The Finance Minister of South Africa presented the Budget for 2017-18 to the Parliament on 22 February 2017. The main tax proposals of the Budget are given below. The 2017/18 tax year sees the introduction of a new top marginal income tax bracket
See MoreSouth Africa: SARS issues rulings on employees’ tax and VAT treatment of non-executive directors
The South African Revenue Service (SARS) issued Binding General Ruling (Income Tax) 40 and Binding General Ruling (VAT) 41 on 10 February 2017. Binding General Ruling (Income Tax) 40 clarifies the employees’ tax consequences of income earned by
See MoreSouth Africa: SARS publishes revised capital gains tax guide
The South African Revenue Service (SARS) has released a revised tax guide regarding capital gains tax (CGT). The tax guide provides guidance on CGT for companies and individuals for the 2017 year of assessment (YA), which covers the period from
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