Davey’s Locker

PRACTICE NOTE (PN) 31 of 1994 TO BE POSSIBLY WITHDRAWN

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Note: In this first newsletter for 2023 we consider the following: Practice Note (PN) 31 of 1994 to be possibly withdrawn Corporate assessed loss limitations time-aligned to corporate tax rate reduction Foreign Pension trust (FPT) continued: Donations tax and...

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FOREIGN PENSION TRUST – SARS ADVANCE TAX RULING

Editors Note: In this sixth newsletter for 2022 we consider the following: Foreign Pension Trust – SARS Advance Tax Ruling (ATR) Two-Pot Retirement System & Tax The Model v SARS – 211/2021 (judgment 20 June 2022), ZASCA Post Facto Public Domain Information and...

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Multiple Annuities and PAYE

In this fourth newsletter for 2022 we consider the following: Multiple Annuities and PAYE; Change of Tax Residence – Procedural Tax Timing Issues and Section 9H; Withdrawing Retirement Benefits as a Non-Resident – The Three-Year Rule; Home Bond Interest Deduction...

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DRAFT COMPENDIUM OF TAXPAYERS RIGHTS

The office of the Tax Ombud (OTO) has published in 2022, a draft Compendium of Taxpayers’ Rights, Entitlements and Obligations vis-à-vis SARS. This is not a legally enforceable Bill of Rights but a compilation of principles contained in the Constitution, Tax...

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BUDGET SPEECH 2022/23 TAX YEAR

1. INDIVIDUALS The maximum marginal rate for natural persons remains at 45% and is reached when taxable income exceeds R1 731 600 (previously R1 656 601). The minimum rate of tax remains at 18% on taxable income not exceeding R226 000 (previously R216 200). The...

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Passing of Costa Divaris – End of a tax era

I note with sadness the passing of Costa Divaris which marks the end of a tax era. Costa was a doyen of the tax world being a co-author of various tax publications including the original standard authority on tax, Silke on South African Income Tax. Costa’s monthly tax...

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Transfer pricing: loans to offshore trusts revisited

SARS establishes a high-net-worth unit The Minister of Finance announced in his Budget Speech 2021 that: SARS will establish a dedicated unit to improve compliance of individuals with wealth and complex financial arrangements. This would naturally, in my view, include...

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SARS in Action

Common reporting standards (CRS) SARS is receiving information and now acting on the CRS automatic exchange of information with eighty-seven foreign jurisdictions concerning RSA taxpayers with offshore investments. Special voluntary disclosure program (SVDP) In...

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