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27 May 2012
                       
 
 
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30 Jan 2012
 
 
When can SARS recharacterise contractual arrangements for taxation purposes?
CLIFFE DEKKER HOFMEYR
Tax planning structures normally involve multiple parties. Sometimes the individuals and/or legal entities involved are inter-connected. The tax benefits generated through such structures, almost...
 
 
22 Jun 2011
 
Special foreign tax credit for management fees
CLIFFE DEKKER HOFMEYR
The normal rule is that SA residents are taxed on their world-wide income. They are then entitled to a tax credit against normal SA tax payable in respect of foreign taxes paid. Thus no foreign tax...
 
 
Unification of source rules
CLIFFE DEKKER HOFMEYR
Since the introduction of residence-based taxation, SA residents are taxed on their world-wide income. In respect of tax paid overseas (on income from abroad), SA residents are eligible for tax...
 
 
 
                       
 
 
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