South Africa: Draft legislative tax proposals

South Africa: Draft legislative tax proposals

Draft tax legislation was released in July 2015 for public comment. Among the proposals are measures that would:


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  • Provide for the consistent tax treatment of all retirement funds and address an estate tax issue that arises when there are excessive contributions to retirement funds
  • Address the tax implications of a transfer of collateral
  • Concern transitional tax issues relating to the regulation of hedge funds
  • Counter tax-free corporate migrations
  • Affect special foreign tax credits for service fees sourced in South Africa
  • Reinstate the controlled foreign company (CFC) diversionary income rules
  • Provide for the collection of information by South African financial institutions and require the financial institutions to register with SARS
  • Extend the period of limitations on assessments under narrow circumstances
  • Clarify voluntary disclosure procedures

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