by Tony Davey | Sep 18, 2023 | Davey's Locker
Editor’s Note: In this sixth newsletter for 2023 we consider the following: Section 9D(9)(b) Foreign Business Exemption for Controlled Foreign Companies. Practice Note 31 revisited. Distributions of income to non-resident beneficiaries to be taxed in resident trusts...
by Tony Davey | Jul 18, 2023 | Davey's Locker
(Arena Holdings (t/a) Financial mail v SARS and others, CCT 365/21 heard 23 Aug and 30 May 2023) Editor’s Note: In this fifth newsletter for 2023 we consider the following: Public interest trumps tax privacy – Concourt judgement. Offshore remittances from RSA by tax...
by Tony Davey | May 17, 2023 | Davey's Locker
Editor’s Note: In this fourth newsletter for 2023 we consider the following: Offshore remittances from RSA by Tax Non-Residents – New TCS process. C,SARS v Coronation Investment Management SA (2023) ZASCA10 – Offshore Asset Management structure. Section 31...
by Tony Davey | Mar 24, 2023 | Davey's Locker
Editor’s Note: In this third newsletter for 2023 we consider the following: Stop Press – Revised Dispute Resolution Rules published. USP Penalties revisited: Thistle & Coronation SCA Judgments Domestic solar PV panels tax rebate and Business Deduction – Budget...
by Tony Davey | Feb 23, 2023 | Davey's Locker
Editors Note: In this newsletter we address salient features of the National Budget, 22 February 2023. Tony Davey – Editor Duncan McAllister – Co-Editor Werner Vos – Consultant 1. INDIVIDUALS The maximum marginal rate for natural persons remains at 45% and is...
by Tony Davey | Jan 16, 2023 | Davey's Locker
Editor’s Note: In this first newsletter for 2023 we consider the following: Practice Note (PN) 31 of 1994 to be possibly withdrawn Corporate assessed loss limitations time-aligned to corporate tax rate reduction Foreign Pension trust (FPT) continued: Donations tax and...
