Of late, there has been a number of developments pertaining to tax disputes. Most notably, the Minister of Finance approved new dispute resolution rules in terms of section 103 of the Tax Administration Act.
Section 31 of the Income Tax Act empowers SARS to alter the tax consequences arising from cross-border financial assistance between connected persons. In a recently published SARS Interpretation Note, it is evident that the manipulation of cross-border pricing to generate undue tax benefits or to artificially allocate profits, may cost corporate taxpayers an arm and a leg.
For years of assessment ending on / after 31 March 2023, a limit will be imposed on the balance of assessed loss of corporate taxpayers.
Effective 16 September 2022, the IT14SD was discontinued. Since its discontinuation, there has been an increase in verification / relevant material requests issued by SARS.
For years of assessment ending on / after 31 March 2023 the corporate income tax rate will reduce from 28% to 27%. How will this impact the annual financial statements?
The Tax Administration Act No. 28 (2011) (“TAA”) allows the South African Revenue Service to provide and procure administrative assistance to and from foreign tax authorities under international tax agreements. Such administrative assistance can be effected in the form of an automatic exchange of information request.
The Tax Administration Act No. 28 (2011) (“TAA”) prescribes the powers and duties of SARS and aims to ensure that tax is effectively and efficiently collected. Of late, however, it has been our experience that there has been an increase in the turnaround time within which SARS attends to corporate tax compliance matters.
For a summary of some of the proposed corporate tax policy and administrative adjustments resulting from the 2022 annual tax policy review,
On 19 January 2022, the 2021 Taxation Laws Amendment Act was promulgated. There are some significant amendments that will impact corporate tax compliance,
For any tax system to be fair, effective and efficient, it has to be flexible. Current international tax rules have created certainty by facilitating the implementation of arm’s length principles and attempting to eliminate double taxation. However, increased digitalisation of various economic sectors has emphasised that the current international tax rules are not adequately designed to accommodate business models that do not require physical presence in an enterprise’s target markets and where value creation is driven mainly by intangible assets.