SOFT LOANS TO NON-RESIDENT TRUSTS REVISITED – BUDGET REVIEW 2024
Editor’s Note: In this third newsletter for 2024 we consider the following: Soft Loans to Non-Resident Trusts revisited – Budget Review 2024 Constitutional Court judgments eagerly awaited in Thistle Trust and Coronation cases Foreign Employment PAYE Limitations Global...
BUDGET SPEECH 2024/25 TAX YEAR
In this newsletter we address salient features of the National Budget, 21 February 2024. Tony Davey – Editor | Duncan McAllister – Co-Editor | Werner Vos - Consultant (tonyd@harding.co.za www.daveyvos.co.za) INDIVIDUALS There are no changes to the rates of tax and...
Final Date for Provisional Taxpayers to Lodge their Income Tax Returns
Editor’s Note: In this first newsletter for 2024 we consider the following: ‘Two-Pot’ Retirement System implementation date 1 September 2024 The Thistle Trust v C: SARS, revisited Bona Fide Inadvertent Error – recent case Amendments to Section 7C Farewell Prof Lindsay...
‘TWO-POT’ RETIREMENT SYSTEM POSTPONED
EDITOR'S NOTES: In this seventh newsletter for 2023 we consider the following: ‘Two-Pot’ Retirement System Postponed PN31 Revisited : The Taxation Laws Amendment Bill, 1 November 2023 CFCs Foreign Business Exemption (FBE) revisited Ponzi Schemes : Capital Losses...
SECTION 9D(9)(b) FOREIGN BUSINESS EXEMPTION (FBE) FOR CONTROLLED FOREIGN COMPANIES (“CFC’S”) – THE SCA CORONATION CASE TRANSFORMS INTO LEGISLATION
Editor’s Note: In this sixth newsletter for 2023 we consider the following: Section 9D(9)(b) Foreign Business Exemption for Controlled Foreign Companies. Practice Note 31 revisited. Distributions of income to non-resident beneficiaries to be taxed in resident trusts...
PUBLIC INTEREST TRUMPS TAX PRIVACY – CONCOURT JUDGEMENT
(Arena Holdings (t/a) Financial mail v SARS and others, CCT 365/21 heard 23 Aug and 30 May 2023) Editor’s Note: In this fifth newsletter for 2023 we consider the following: Public interest trumps tax privacy – Concourt judgement. Offshore remittances from RSA by tax...
Adv. Anthony (Tony) Harding Davey
Editor
Tony is a co-author of Broomberg on Tax Strategy (Lexis Nexis). He is also the columnist for Costa Divaris’ (ex Silke on Income Tax) monthly tax newsletter as well as the South African contributing author to two international publications Planning and Administration of Offshore and Onshore Trusts (Bloomsbury Publishing Plc) and Tolley’s International Succession Laws (STEP). He appears as a guest tax adviser on Summit T.V. Prior to establishing the firm, Tony acted as General Counsel to three JSE-listed financial services companies. As a member (honorary Status Conferred in 2014) of the National Bar Council of SA (previously IAASA), Tony negotiates Alternate Dispute Resolution and litigates before the Tax Board and Court.