Foreign exchange , non residents and residents
Articles pertaining to non residents , residents world wide assets and income as well as foreign exchange matters
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...
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...
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...
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...
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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...
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 ...
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...
1172. Offshore bank accounts
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 ...