Author: Beric Croome (ENS) During the course of September, 2013, the leaders of the G20 nations met in St Petersburg to deal with a number of matters. Pursuant to that meeting, a tax annex to the St Petersburg G20 Leaders’ Declaration was released. At the outset, it is appropriate to point out that the members of the G20 comprise the European Union together with the following 19 countries: Argentina, Australia, Brazil, Canada, China, France, Germany, Italy, India, Indonesia, Japan, Mexico, the Republic of Korea, Russia, Saudi Arabia, South Africa, Turkey, the United Kingdom and the United States.
Category: International Tax
Reform R&D Tax Systems To Boost Innovation And Help Young Firms, Says OECD
Author: OECD Most OECD governments use tax incentives to encourage businesses to invest in research and development (R&D) to boost innovation and drive economic growth. Others, like China, India and South Africa, are doing the same. But reforming these incentives would give countries a better return on their investment and support young innovative firms that play a crucial role in job creation, according to a new OECD report.
Taxation of Foreign Dividends
Author: Tarryn Spearman(Grant Thornton) Significant changes were introduced to the way foreign dividends, received by South African residents, are treated for tax purposes. The purpose of these changes is to eliminate the disparity between the tax treatment of domestic and foreign dividends.
Cyprus: A Further Step Towards Ratification Of The Cyprus – Spain Double Taxation Agreement
Authors: Andreas Neocleous & Co LLC The double taxation agreement between Cyprus and Spain, which was signed in Nicosia on 14 February 2013, has taken another step towards ratification. On 2 August the Spanish cabinet approved the agreement and forwarded it the Spanish parliament for consideration. The new agreement follows the OECD Model Convention
SA’s Double Tax Agreement with Mauritius Amended
SA’s Double Tax Agreement with Mauritius Amended Author: Bernard du Plessis (ENS) The double tax agreement between Mauritius and South Africa, which came into force in 1997 has been renegotiated. There are three main amendments to the 1997 double tax agreement: the resident article has been amended, the allocation of taxing rights in relation to immovable property assets has been renegotiated, and the interest article has been amended.
Personal tax consequences for South African executives on foreign boards – the Netherlands as an example
Introduction South African companies are increasingly looking to global expansion to build their capabilities and expand their operations into foreign jurisdictions. Where South Africans serve on the boards of foreign companies and render services to foreign entities, they typically do so in terms of split employment contracts in respect of their services rendered within and outside of South Africa. In addition to the remuneration, they may also receive directors’ fees for services rendered to the boards. Their employment contracts with the foreign company and the requirement that such services must be rendered outside of South Africa, are essential to ensure that these foreign entities are effectively managed in the countries where they are registered, and not in South Africa.
A Departure From ‘Adequate Reasons’ and Common Sense
Author: Daniel Areias & Johan Kotze (Bowman Gilfillan) All taxation , in one way or another, may impact upon fundamental human rights. However, to ensure that the imposition is not absolute, section 5 of the Promotion of Administrative Justice Act provides that every person, whose rights may have been materially and adversely affected by administrative action, may request written reasons for that action from the administrator responsible.
Krok heir faces R228m tax bill
Pretoria – Mark Krok, billionaire heir to an apartheid-era skin-lightening company, will be about R228m poorer if the SA Revenue Service (Sars) and the Australian Tax Office (ATO) have their way. The Sunday Times reported that Sars, on behalf of the ATO, is seeking an order to ring-fence Krok’s local assets – including a R37.5m mansion in Clifton, Cape Town, as well as vast chunks of pharmaceutical company Aspen and casino company Tsogo Sun. In 2006, Australia kicked off Operation Wickenby, targeting high-profile tax evaders – and their lawyers and accountants – who have set up shell companies and trusts in tax havens to evade the Australian tax office. Maxim Krok, Mark’s estranged half-brother, has also come under the spotlight. In 2010, the ATO unleashed investigators to scrutinise his tax records.
High Court Rejects Challenge of Exchange Control Ruling
Billionaire entrepreneur Mark Shuttleworth emigrated from the Republic in February 2001. Following his emigration, he made applications to transfer portions of his blocked funds from the Republic. In the second of these (in 2008) he was permitted to remit funds subject to a levy equal 10% of the amount remitted.
Status Overviews of International Treaties and Agreements Updated
Author: SARS Legal and Policy On the 7th of August 2013 SARS released updated overviews of various international treaties and agreements. To view the update on “Double taxation agreements & protocols” click here: To view the update on “Customs MAA’s” click here: To view the update on “Exchange of Information Programs” click here: To view the update on “One-Stop-Border-Post Agreements” click here: