by Tony Davey | Dec 20, 2020 | Davey's Locker
Change of tax-residency status I have already canvassed the criteria governing the change of residence of an RSA resident (see 192, 200 TSH 2019). In essence, one must have regard to: Any applicable double tax agreement. The case law on the expression ‘ordinarily...
by Tony Davey | Oct 9, 2020 | Davey's Locker
Taxpayers raising the procedural defence of prescription to a notification from SARS demanding tax payment of an amount of some historic tax year must distinguish between a prescribed assessment and a historic tax debt, since different prescription periods apply. For...
by Tony Davey | Sep 14, 2020 | Davey's Locker
Access upon emigration National Treasury has issued a draft Explanatory Memorandum on the Draft Taxation Laws Amendment Bill 2020, dated 31 July 2020. Under para 1.4 of the Explanatory Memorandum, the proposal is made to amend the definitions of a ‘pension...
by Tony Davey | Sep 9, 2020 | Davey's Locker
In 180 TSH 2018 I referred to what I described as a sui generis exception to s 7C of the Income Tax Act (deemed donation of non-charging of official rate of interest), namely a loan advance or credit in circumstances in which trustees vest an amount in a trust...
by Tony Davey | Jul 10, 2020 | Davey's Locker
Tax Ombud’s report 2020 Tucked away in point 38.2 of the sixty-one-page Report and occupying only a half-page is, in my experience of the tax dispute-resolution process, a valuable finding and recommendation by the Tax Ombud, on non-meritorious additional assessments:...
