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. . .
A new tax treaty between Hong Kong and South Africa entered into force on October 20, Hong Kong’s Inland Revenue Department . . .
The South African Revenue Service on February 12 released draft guidance interpreting special tax incentives for headquarters companies, designed to encourage MNEs to locate operations in South Africa as a gateway to African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. . .
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. . .
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. . .
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.
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 . . .
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 . . .
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 . . .
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 . . .
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
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 . . .
Hong Kong and South Africa have signed an agreement for the avoidance of double taxation and . . .
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 . . .
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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