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...
OFFSHORE REMITTANCES FROM RSA BY TAX NON-RESIDENTS – NEW TCS PROCESS
Editor’s Note: In this fourth newsletter for 2023 we consider the following: Offshore remittances from RSA by Tax Non-Residents – New TCS process. C,SARS v Coronation Investment Management SA (2023) ZASCA10 – Offshore Asset Management structure. Section 31...
REVISED DISPUTE RESOLUTION RULES
Editor’s Note: In this third newsletter for 2023 we consider the following: Stop Press – Revised Dispute Resolution Rules published. USP Penalties revisited: Thistle & Coronation SCA Judgments Domestic solar PV panels tax rebate and Business Deduction – Budget...
BUDGET SPEECH 2023/24 TAX YEAR
Editors Note: In this newsletter we address salient features of the National Budget, 22 February 2023. Tony Davey – Editor Duncan McAllister – Co-Editor Werner Vos – Consultant 1. INDIVIDUALS The maximum marginal rate for natural persons remains at 45% and is reached...
PRACTICE NOTE (PN) 31 of 1994 TO BE POSSIBLY WITHDRAWN
Editor’s Note: In this first newsletter for 2023 we consider the following: Practice Note (PN) 31 of 1994 to be possibly withdrawn Corporate assessed loss limitations time-aligned to corporate tax rate reduction Foreign Pension trust (FPT) continued: Donations tax and...
C: SARS v THE THISTLE TRUST – THE SCA CONFIRMS THAT CAPITAL GAINS CANNOT FLOW THROUGH MULTIPLE DISCRETIONARY TRUSTS
Editors Note: In this seventh newsletter for 2022 we consider the following: C.SARS v The Thistle Trust Judgement – CGT downside for multiple trust structures First Tax Ombud’s Term of Office Expires SARS BCR 080 Revisited: Foreign Pension Trust and Estate Duty SARS...
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.