On 17 January 2023 the South African Revenue Service (SARS) issued Interpretation Note 127 (IN 127) providing long awaited guidance as to the treatment of cross-border intra-group funding transactions for transfer pricing purposes.
If you have been living outside of South Africa for an extended period of time or regard yourself as a person who has emigrated from South Africa, this document is important for you to read.
Have you accepted the responsibility as a fiduciary representing a Public Benefit Organisation (“PBO”) and do you know what you are responsible for?
It is proposed that changes be made to the VAT Act by the insertion of section 18D which will deal with the deemed change in use adjustment required when a dwelling is let for the first time if the dwelling remains permanently in the scope of VAT and the deemed supply made when the dwelling is subsequently sold. Section 18D is proposed to come into effect on 1 April 2022.
Since the forced lockdown experienced in 2020, many employees have had to work from home. In some instances, due to a shift in corporate culture, employees have chosen to continue this practice by no longer travelling to a fixed office on a daily basis. In some cases people have converted space at their home to function as their home office.
It has been more than three years since SARS’s media statement on cryptocurrencies. In this statement SARS stated that it will apply “normal income tax rules” to cryptocurrencies when assessing whether a gain is revenue or capital in nature and that crypto assets are not seen as currency for income tax purposes.
With the global online age it is easy for a taxpayer to advertise and rent out part of their home, or investment property, to paying guests. Many people are using online platforms, who can then monitor booking and assist with the logistics in the collection of the rental income. As easy as it is for a home owner to add his property to such an online site, so, can SARS, as the “prospective”...
On 31 August 2020, the South African (“SA”) Tax Court delivered judgement in the case referred to as SARSTC 14302. The court ruled against the taxpayer in respect of an application for discovery of documents relating to an underlying transfer pricing assessment matter. The case, as well as the underlying transfer pricing dispute, are briefly summarised below.
An APA is an agreement between a taxpayer and SARS in terms of which the transfer pricing methodology for the pricing of a taxpayer's cross-border related party transactions are determined in advance for future years.
On 12 November 2020 the South African Revenue Service (SARS) issued a notice extending the deadline for the submission of Country-by-Country Returns (CbCR) under Notice No. 1117 published in Government Gazette No. 41186 dated 20 October 2017, for Reporting Fiscal Years commencing before 1 March 2020.
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