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The South African Revenue Service (SARS)

SA multinationals need to collate evidence

Offshore companies that are, directly or indirectly, owned by South African residents may be regarded as Controlled Foreign Companies (‘CFC’) for South African income tax purposes.As such, a proportionate amount of the ‘net income’ of…

Empowerment: an interesting ruling regarding a BEE transaction

In 2016, the BEE regulatory landscape has seen a number of changes introduced. These include the final regulations that were issued under the Broad-Based Black Economic Empowerment Act, No 53 of 2003 (BBBEE Act), the…

re SA’s controlled foreign company rules aligned with economic globalisation?

SA’s international tax laws regarding controlled foreign companies (CFCs) have not entirely kept pace with the advent of globalisation and technology – they are rigidly mechanical and may not cater for the bona fide business…

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