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South Africa

Africa

Ireland tax treaty update: agreements with Zambia, Germany, Luxembourg enter into force; pacts with Ethiopia, Pakistan ratified; new treaty with South Africa under negotiation

January 12, 2016

Ireland’s tax treaty with Zambia and protocols to tax treaties with Germany and Luxembourg have entered into force and effect, Irish Tax and Customs. . .

Asia-Pacific

Hong Kong, South Africa tax treaty enters into force

November 3, 2015

A new tax treaty between Hong Kong and South Africa entered into force on October 20, Hong Kong’s Inland Revenue Department . . .

Africa

South Africa’s SARS provides guidance on tax breaks for headquarters companies

February 12, 2015

The South African Revenue Service on February 12 released draft guidance interpreting special tax incentives for headquarters companies, designed to encourage MNEs to locate operations in South Africa as a gateway to African investment. The law, effective for tax years after January 1, 2011, provides special tax breaks for qualifying. . .

Africa

Hong Kong gazettes orders on tax treaties with South Africa, UAE, and Japan

May 15, 2015

Hong Kong on May 15 announced that orders were gazetted to implement tax treaties signed with South Africa and the United Arab Emirates and notes exchanged with Japan regarding interpretation of the 2010 Japan/Hong Kong treaty. The tax treaty with South Africa, signed October 2014, reduce. . . 

Africa

South Africa-Mauritius tax treaty enters into force

June 19, 2015

The South African goverment has announced that a new tax treaty with Mauritius was gazetted on June 17 and thus entered into force on May 28. The treaty, signed May 17, 2013, replaces. . .

Africa

South Africa publishes guide to implement FATCA

December 17, 2014

The South African Government, on December 17, released on its website a draft guide for financial institutions. The guide deals with issues arising from an intergovernmental agreement signed by South Africa and United States under FATCA. See, Guide.

Africa

South Africa proposal permits tax-free cross-border share-for-share deals, limits use of participation exemption-

June 5, 2015

The South Africa National Treasury announced in a June 5 media statement that the government intends to introduce draft legislation providing that issuance of shares by a South African resident company as consideration . . .

Africa

Moyane appointed SARS Commissioner

September 23, 2014

Thomas Swabihi Moyane has been appointed Commissioner of the South African Revenue Services effective Sept. 27, President Zuma has announced.

Africa

South Africa report considers how to react to OECD/G20 BEPS work

December 23, 2014

South Africa’s minister of finance on December 23 released for public comment a draft report that provides a detailed analysis of how South Africa should react to OECD/G-20 base erosion and profit shifting (BEPS) plan output . . .

Africa

New South African tax guidance explains “place of effective management” test

November 11, 2015

Ashish Goel reviews the South African Revenue Service’s final guidance, released November 3, on the “place of effective management” test, used to determine a company’s tax residence for treaties.

Africa

Draft South African rules impose heightened transfer pricing recordkeeping requirements

December 15, 2015

The South African Revenue Service on December 15 issued draft rules requiring companies that have consolidated South African turnover of R1 billion and above to keep . . .

Africa

South Africa budget includes plan to rewrite rules on transfer pricing documentation, digital businesses

February 25, 2015

South Africa’s government intends to propose new transfer pricing documentation and reporting rules and to revise controlled foreign company (CFC) rules relating to the digital economy, according to 2015 budget documents released February 25. The proposals will be “in line with” the OECD work . . .

South Africa

South Africa rules that restructuring involving German partnership is tax free

August 15, 2014

The South African Revenue Service, on August 14, released a binding private ruling involving the proposed restructuring of a multinational group, concluding that a German Kommanditgesellschaft is a company for South African tax purposes and that the proposed restructuring did not give rise to tax, including capital gains tax. BPR 178

Africa

South Africa publishes draft bill proposing carbon tax, requests public comment >> National Treasury

November 2, 2015
OECD
Africa

OECD publishes MAP statistics of member countries

November 25, 2014

The OECD on November 25 released 2013 statistics on the mutual agreement procedure (MAP) caseload of OECD member counties and partner economies of Argentina, China, Latvia, and South Africa. According to an accompanying OECD . . .

Africa

Hong Kong and South Africa sign double tax treaty – text available

October 17, 2014

Hong Kong and South Africa have signed an agreement for the avoidance of double taxation and . . .

Africa

South Africa issues draft guidance on determining entity residence

April 14, 2015

The South African Revenue Service has released draft guidance to assist in determining whether an entity has an place of effective management in South Africa so as to be considered a resident of the Republic. The guidance concludes . . .

Africa

South Africa Parliament considering loosening rules on loan deductibility in controlling relationships

November 5, 2014

A tax bill tabled in South Africa’s parliament on October 22 proposes taxpayer-favorable changes to Section 23M of the Income Tax Act, which limits interest that can be deducted on loans from a person that is an a “controlling relationship,” with the debtor, notes KPMG in an October report. For details, see KPMG.

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