What happens during liquidation?
The South African Revenue Service (“SARS”) issued Binding Private Ruling 336 on 6 December 2019. In terms of this ruling, a listed resident company (“the Company”) previously granted a loan to its wholly-owned resident subsidiary (“the Subsidiary”) in order for the Subsidiary to acquire shares in the Company. The Company subsequently decided to deregister the […]
Doubling down on income taxes
The purpose of double tax agreements (“DTA” or “treaty”) between the tax administrations of two countries is to enable the administrations to eliminate double taxation, where each country intends to levy a tax in respect of the same amount of personal income. South Africa has a very favourable treaty network across the world. Generally, the […]