Section 42: Asset-for-share transactions
It is often the case that South African tax resident shareholders wish to reorganise their South African group of companies, for a multitude of commercial reasons, without the ultimate shareholders changing. One of these could potentially be to create a single holding company structure. Various group relief provisions are contained in the Income Tax Act […]
How to become a DTMC
In 2013, the South African government introduced the Domestic Treasury Management Company (DTMC) regime to allow South African companies that are registered with the Financial Surveillance Department (FinSurv) of the South African Reserve Bank (SARB) to expand into the rest of Africa and abroad. The DTMC Regime, in essence, allows unlisted companies to establish one subsidiary […]
How will the 2022 budget changes affect you?
The annual National Budget Speech was delivered on 23 February 2022 by Finance Minister Enoch Godongwana. Practitioners are getting to grips with some of the more pertinent changes that will become a reality for taxpayers, particularly in the individuals, employment and savings areas. Reviewing the timing of accrual and incurral of variable remuneration Section 7B […]
“Exit Charge” on ceasing to be a tax resident
Section 9H of the Income Tax Act deals with matters relating to the cessation of residency in South Africa. This section essentially states that where a person that is a resident ceases to be a resident during any year of assessment, that person must be treated as having disposed of his assets on the date […]