Archive | November, 2014

S.Africa: the thin capitalisation provisions of section 23M and further amendments proposed thereto

the thin capitalisation provisions of section 23M and further amendments proposed thereto by Okkie Kellerman and Esther Geldenhuys In line with recent pronouncements by the OECD relating to so-called Base Erosion and Profit Shifting Project (BEPS), section 23M was introduced by the Taxation Laws Amendment Act, 31 of 2013.  Section 23M of the Income Tax Act, 58 of 1962 (“the […]

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S.Africa: Landmark judgment in Supreme Court of Appeal upholds deferred delivery share scheme

Landmark judgment in Supreme Court of Appeal upholds deferred delivery share scheme Commissioner SARS v Bosch (394/2013) [2014] ZASCA 171 (19 November 2014)Share option scheme – s 8A(1)(a) of the Income Tax Act 58 of 1962 – employees given option to purchase shares – option to be exercised within 21 days – payment for and delivery of shares to occur in tranches two, four and six […]

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