Tax Alert - September 2014

We provide a wealth of publications by PwC South Africa providing informed commentary on current developments in the tax arena, both locally and internationally. Through analysis and comment on new law and judicial decisions of interest, they assist business executives to identify developments and trends in tax law and revenue practice that might impact their business.

Base Erosion and Profit Shifting – the OECD releases the first batch of proposals that will bring about the most significant reform of the international tax system since the 1950s.

In September 2013, G20 Leaders fully endorsed the OECD Action Plan to address Base Erosion and Profit Shifting (“BEPS”). The Action Plan provides for 15 actions to be delivered by 2015, with 7 actions to be delivered in September 2014. True to this timeline, on 16 September 2014 the OECD released the first 7 deliverables, together with an official Explanatory Statement.

The seven topics covered by the 16 September reports are:

  • The Tax Challenges of the Digital Economy.
  • Hybrid Mismatch Arrangements
  • Harmful Tax Practices
  • Tax Treaty Abuse
  • Transfer Pricing & Intangibles
  • Transfer Pricing Documentation and Country-by-Country Reporting
  • The Feasibility of Developing a Multilateral Instrument on BEPS



Electronic services –VAT registration implications

In line with the new legislation, set to take effect on 1 April 2014, electronic services supplied by a business outside South Africa to a recipient in South Africa will require the supplier of such services to register for Value-Added Tax (VAT).

The Taxation Laws Amendment Act amended the definition of 'enterprise' in the VAT Act to now include the supply of 'electronic services' by a person from a place outside South Africa to a recipient, where that recipient is a resident of South Africa, or where any payment originates from a bank registered or authorised in terms of South African law.


VAT Alert 2014
VAT Alert 2013
VAT Alert 2012
VAT Alert 2011
VAT Alert 2010
VAT Alert 2009

An Overview of the Dispute Settlement of the World Trade Organization

In light of increasing trade tensions between South Africa and other partners, notably the European Union, this alert seeks to inform relevant stakeholders of the WTO dispute settlement procedures, as well as the effectiveness of addressing the differences between two WTO members ('WTO members' is the term of art given to the countries that are members of the WTO, such as South Africa and the EU) within the mechanism provided under the WTO.


Trade Alert 2013

On-Site Verification: Be aware of the potential impact on your business

The South African Revenue Service's Customs National Audit team has developed and is deploying an intensive information gathering exercise whereby detailed information is sought regarding the respondent's business. This on-site verification process is a precursor to the implementation of the revised Customs and Excise Act, 1964 ("the Customs Act") anticipated to be made effective in the third quarter of 2010. With greater emphasis on Customs' clients being selfcompliant, the National Audit Team appear to be preparing for the implementation of this new legislation by enhancing the customs to business interactions.


Customs Alert 2010
Customs Alert 2009