Archive | February, 2018

2018 South African Budget Speech

South Africa Report from our correspondent Lutando Mvovo, South Africa Budget for 2018-19 – direct taxation The Budget for 2018-19 was presented to Parliament by the Minister of Finance on 21 February 2018. Details of the Budget with respect to direct taxation, which, unless stated otherwise, will apply from 1 March 2018, are summarized below. […]

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US: GILTI onerous for non-C corporation CFC shareholders

GILTI rules particularly onerous for non-C corporation CFC shareholders McDermott Will & Emery USA February 9 2018 Summary The recently enacted tax reform legislation significantly expanded the application of Subpart F, including by adding a new inclusion rule for non-routine CFC income, termed “global intangible low-taxed income” (GILTI). The GILTI rules apply higher tax rates to […]

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S.Africa: When to expect a transfer pricing interpretation note?

When to expect a transfer pricing interpretation note? 2018/19 South African National Budget Expectations By Billy Joubert, Deloitte. South African corporate taxpayers have, over the past few years, been subjected to a barrage of additional transfer pricing compliance requirements. These have included compulsory documentation requirements, the requirement to submit Country-by-Country (CbC) reports plus onerous additional […]

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S.Africa: Taxpayer wins case against SARS’ failure to issue a Letter of Findings at the conclusion of a tax audit

S.Africa: Taxpayer wins case against SARS’ failure to issue a Letter of Findings at the conclusion of a tax audit I am pleased to inform you that a recent tax case I argued in PE (with colleagues Strombeck Pieterse Attorneys) was won with costs against SARS. The case has been redacted due to it being […]

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