ENSafrica provides a snapshot of the latest tax developments in South Africa.
Advance tax rulings
Binding private ruling 304: debt reduction and subsequent liquidation of debtor
Binding private ruling 305: registration of units in the name of the beneficial owners
Binding private ruling 306: donation to a special trust
SARS publications
SARS publishes the Guide on Income Tax and the Individual (2017/2018)
SARS publishes the Draft Guide on Venture Capital Companies
Interpretation note 3 (issue 2): definition of residence in relation to a natural person – ordinarily resident
Interpretation note 9 (issue 7): small business corporations
Interpretation note 51 (issue 5): pre-trade expenditure and losses
Exchange control
Exchange control circular no. 11/2018
SARB publishes updated manuals
International
The Organisation for Economic Cooperation and Development (OECD) releases new guidance on the application of the approach to hard-to-value intangibles and the transactional profit split method under base erosion and profit shifting (BEPS) actions 8 and 10. The new guidance amends the specified sections of the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations
The OECD receives public comments on the scope of future revisions of chapter iv (administrative approaches) and chapter vii (intra-group services) of the Transfer Pricing Guidelines
The OECD and the African Tax Administration Forum have signed a renewal of their memorandum of understanding until June 2023 to continue to work together to improve tax systems in Africa
The OECD and the Intergovernmental Forum on Mining, Minerals, Metals and Sustainable Development (IGF) invite comments on a draft toolkit (The Hidden Costs of Tax Incentives in Mining), as part of the IGF-OECD programme to address BEPS in mining, that will help developing countries to identify and cost potential behavioural responses by mining investors to tax incentives
