Articles pertaining to non residents , residents world wide assets and income as well as foreign exchange matters

International Tax 1786. Controlled foreign companies November 2009 - Issue 123     In general, South African residents are required to impute into their net income an amount equal to the net income derived by controlled foreign compani...

Exchange Control 1747. Approvals required July 2009 – Issue 119   In recent times we have seen a number of cases of companies which have entered into a transaction without the necessary exchange control approval, purely because they wer...

International Tax1730. Residence of a company for tax purposes?May 2009 – Issue 117 In a state (such as South Africa) whose tax system is residence-based, in other words, which imposes tax on all persons "resident" in that state, the ...

Exchange Control1690. Loop structuresDecember 2008 – Issue 112 Inward listings have become a common feature of recent international transactions involving South Africa. The recent primary listing of Pallinghurst Resources Guern...

Exchange Control 1879. Voluntary disclosure programme October 2010 - Issue 134   As foreshadowed in an announcement by the Minister of Finance his Budget Speech of 17 February 2010, the Exchange Control Department of the South African Res...

International Tax 1882. Permanent establishment in respect of services rendered October 2010 - Issue 134     Article 5(1) of most Double Taxation Agreements ("DTA’s") concluded between contracting States provides that a per...

News function DoThis(){ var sClean = '' for(a=0;a Pretoria, 5 November 2010 – Individuals and corporate entities who took funds offshore illegally and those who defaulted on their tax affairs now have the opp...

International Tax 1893. Setting the right royalty rate November 2010 - Issue 135     Globalisation and technological advances are changing the shape of the world economy. With the increase in international transactions in a globalised ...

  Non Residents 1910. Withholding tax on interest January 2011 - Issue 137     In terms of the 2010 Draft Taxation Laws Amendment Bill, interest earned by non-residents in future, would only be exempt in certain limited inst...

Exchange Control 1172. Offshore bank accounts April, 2004     A recent query from a practitioner highlights some of the tax issues facing taxpayers with offshore bank accounts.   The query concerned a resident individu...

In view of the relaxation in exchange control announced by the Minister of Finance in the Medium-Term Budget Policy Statement, presented to Parliament during October 2009, South African residents may now invest up to R4 million abroad. Questions are ...