Proposed change to FBE exemption ‘ignores the realities of global outsourcing’
The practical challenges associated with applying the amendment will make it difficult for SA multinationals to qualify for the tax exemption.
The practical challenges associated with applying the amendment will make it difficult for SA multinationals to qualify for the tax exemption.
The Supreme Court of Appeal’s judgment in the Coronation case finds its way into proposed amendments to the ‘controlled foreign company’ rules.
The amendments encompass debt denominated in a foreign currency and the primary residence exclusion.
One amendment will affect inter-fund transfers by members who have reached normal retirement age but who have opted not to retire.
An anomaly in the Act results in the creation of two years of assessment during a single 12-month period when an individual ceases to be a tax resident.