Tax synopsis

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Synopsis Tax today - June 2020

A monthly journal, published by PwC South Africa, that gives informed commentary on current developments in the tax arena, both locally and internationally. 

Through analysis of and comment on new laws and judicial decisions of interest, Synopsis helps executives to identify developments and trends in tax law and revenue practice that may affect their business.

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In this edition:

We look at reimagining the supply of financial services from a VAT perspective, as we analyse the recent judgement in the matter of ABC (Pty) Ltd v CSARS (VAT 1626) [2020] SARSTC. This judgment provides guidance on the principle of direct attribution and the interpretation of financial services.

We discuss the recent case of Fowler v HMRC [2020] UKSC 22, the matter for decision was whether the income derived by Mr Fowler (‘MF’), a deep-sea diver who performed services related to exploration on the continental shelf in UK waters, was income from employment or income from a trade or business. MF was at all relevant times a resident of South Africa. Notwithstanding that this was a judgment of the UK courts, it makes important points that would be equally applicable in South Africa to interpretation of the words used in double tax agreements.

The South African Revenue Service (‘SARS’), by law, is tasked with assessing and collecting taxes. However, in these trying economic times, it is likely that many taxpayers may find themselves in a situation where they are unable to pay their outstanding tax debts to SARS (even with the current draft tax relief measures which have now been introduced in Parliament). The Tax Administration Act, No. 28 of 2011 (‘TAA’) contains additional tax relief measures that may assist financially distressed taxpayers to manage the payment of their tax debts to SARS. One such relief measure is a request for a compromise of debt (or compromise agreement).

Read more on this and other matters in the latest Synopsis below.


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Edition: Tax synopsis - June 2020

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Al-Marie Chaffey

Al-Marie Chaffey

Senior Manager , PwC South Africa

Tel: +27 (0) 11 797 5644

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