Double taxation a headache for SA corporates

By IngĂ© Lamprecht African countries are turning to tax collection. JOHANNESBURG – After a number of years where some African countries have generally focused on attracting investment, developing infrastructure and creating jobs, a number of countries are now turning their attention to tax collection in an effort to supplement their state coffers.

UK Court decision on corporate tax residency

Written by: Justin Liebenberg, Director Cliffe Dekker Hofmeyr Tax A company incorporated outside South Africa can be tax resident here if its place of effective management (POEM) is located in South Africa. POEM is also often used as the tie-breaker to finally determine corporate tax residency under double tax agreements. A recent court decision in the UK sheds further light on POEM especially in the context of a double tax agreement.