Case Law Wrap-Up
Commissioner for SARS v Coronation Investment Management SA (Pty) Ltd (1269/2021) [2023] ZASCA 10 (07 February 2023) The issue before the Supreme Court of Appeal (SCA) in this matter was whether a controlled foreign company (CFC) constituted a foreign business establishment (FBE) as contemplated in the Income Tax Act, No. 58 of 1962 (the ITA).
Shades of Grey: SARS Clearances and Greylisting
The greylisting of South Africa by the Financial Action Task Force (FATF), due to concerns about the country’s anti-money laundering efforts, has had significant consequences for individuals and businesses operating within South Africa. One of the key impacts of greylisting is the increased scrutiny of cross-border financial transactions, particularly with the remittance of funds out […]
SARS Overhauls Trust Returns: 5 Major Changes
SARS has completely overhauled tax returns for trusts. Although this has been hinted at for a long time, the degree of overhaul is far from expected.
“Exit Tax”: Detrimental or Desirable; What You Need to Know
When pursuing international career growth, and offshore employment, be aware that moving your person, without the requisite paperwork, will have you scoring bonuses in Belgium, but still subject to SARS in South Africa. In order to ensure optimal taxation, South Africans abroad must make use of either the Double Tax Agreement or Financial Emigration process […]
Time To Count Your Chickens: SARS Has Changed The Tax Compliance Status Process
With no fanfare or any prior notification, on 24 April 2023, SARS released new enhancements to the Tax Compliance Status (TCS) process, and with immediate effect. These changes will be directly felt by specific taxpayers seeking to transfer funds out of South Africa and will effectively change the ball game for those who have ceased […]