Synopsis June 2019
We analyse the recent Western Cape High Court decision in the matter of Mark Roy Lifman and others v Commissioner for the South African Revenue Service and others (Case No 22820/2016).
Tax synopsis
Latest edition:
Synopsis Tax today - October 2019
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.
In this edition:
We discuss inventory accounting practices and taxation whilst analysing the decision of the Supreme Court of Appeal in the matter of CSARS v Atlas Copco South Africa (Pty) Ltd.
Under tax policy developments we comment on the proposed amendment in this year’s Taxation Laws Amendment Bill (‘the TLAB, 2019’) to section 31 of the Income Tax Act, 1962. The proposed amendment introduces the concept of ‘associated enterprise’ into section 31 of the Act and expands the scope of the transfer pricing rules to include transactions between persons that are ‘associated enterprises’ as described in the OECD Model Tax Convention.
Article 10 of the ‘Tax Director Series’ looks at the responsible taxpayer through a new lens of transparency in relation to corporates as a visible and valuable part of society.
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Edition: Tax synopsis - October 2019
Previous editions
Synopsis May 2019
With the recent promulgation of the Carbon Tax Act, 2019 (No. 15 of 2019), we discuss key considerations surrounding the practicalities and difficulties around the implementation of carbon tax.
Synopsis April 2019
We discuss a recent Western Cape Tax Court decision which considers when the consideration given for a gift card is taxable. In addition we publish the 4 th article in the Tax Director Series.
Synopsis March 2019
We discuss a Tax Court decision which considers the application of the section 24C allowance in the context of loyalty programmes, as well as a Supreme Court of Appeal decision which considers the definition of "mining" and "mining operations" in section 1 of the Income Tax Act. We also publish the 3rd article in the Tax Director Series.
Synopsis February 2019
This synopsis examines the implications of the decision of the Dutch Supreme Court on the "most favoured nation " clause in the treaty between South Africa and the Netherlands. Locally, we look at a case where the SCA pronounces on the powers of the Tax Court in regard to the imposition of penalties.
Synopsis January 2019
The section 24C future expenditure allowance and the contractual link. Do services provided at the expense of an employer equate to a taxable fringe benefit? Article 1 in our new Tax Director series: Align tax with the business strategy.
Synopsis November and December 2018
It has been some time since the panel of justices in the Supreme Court of Appeal (‘SCA’) has expressed anything other than unanimity in the adjudication of taxation-related appeals.
Synopsis October 2018
The SA Income Tax Act, is just that: a single Act of Parliament that has been regularly amended (by more than 100 amending Acts of Parliament and Government Notices) since 1962.
Synopsis September 2018
Over the past two years, we have discussed the valuation of trading stock for purposes of the Income Tax Act and the decisions reached in the Tax Court on this issue.
Synopsis August 2018
South Africa is a relatively small player on the world economic stage, and there are sound reasons why it is in the national interest to learn from, and to remain in step with, the country’s more powerful trading partners and major economic powers .
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