Interaction of taxes

CGT, estate duty and income tax upon death Any tax-structuring should always take cognisance of its impact on other taxes. For CGT purposes, the default position is that a deceased person is assessed on a ‘deemed disposal’ as at date of death, with the death-exclusion...

Excess contributions to provident funds

Relief coming soon In circumstances in which annual tax-deduction limits to retirement fund contributions are exceeded, a taxpayer may carry forward the nondeductible portion to the following tax year, under s 11F of the Income Tax Act.Ultimately, upon retirement,...

Provident fund annuitisation revisited

Tax harmonisation of retirement fund contributions As from 1 March 2016, all contributions to retirement funds (pension, provident and retirement annuity funds) are treated similarly for tax-deduction purposes, under s 11F of the Income Tax Act. The tax-deduction...

Soft loans to nonresident trusts revisited

And more on s 7C of the Income Tax Act In 168 TSH 2017, I examined the interaction between the various sections of the Income Tax Act pertaining to resident funders of nonresident trusts. It is time to revisit this topic. Attribution rules (s 7(8))Section 7(8)...