Foreign employment income amendments
Myths abound ‘Financial emigration’ Amidst the panic created by the amendments to s 10(l)(o)(ii) of the Income Tax Act, which, with effect as from 1 March 2020, will subject to tax in the RSA foreign employment income in excess of R1 million earned by RSA taxpayers...
Section 7C revisited
Dynamic tax environment can create opportunities Sometimes amendments to the tax legislation, albeit unwittingly, can have favourable results for a taxpayer. As the saying by the inventor, Alexander Graham Bell, goes, ‘when one door closes, another opens’. An example...
Late objections and appeals
Issue 5 of Interpretation Note 15 On 21 December 2018, SARS issued an updated Interpretation Note 15 (Issue 5). This pertains to the exercise of a senior SARS official’s discretion to condone a late objection or appeal. The legal principles underlying the relevant...
Donations tax conundrums
Festive gifts It’s the festive season and ’tis the season for giving. Maybe it is coincidental that the topic of donations to political parties, high-profile persons and others features prominently in the press. Donations tax is levied by s 54 of the Income Tax Act,...
Externalising a business – The Sequel
In last month’s article (187 TSH 2018) I examined the concept of ‘effective management’ as dealt with in the SARS Interpretation Note 6 (Issue 1). A reader, Patrick Emmett, a senior tax consultant at Mazars, has correctly pointed out that SARS has also published an...
Externalising a business – Tax factors to consider
In the scramble for the externalisation of investments as a rand hedge, using the annual foreign R1 million discretionary and R10 million investment allowances, schemes to externalize a business or part of it are surfacing. Place of incorporation The definition of...
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.