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2017 - 14 Feb 2017

Highlights of the Double Taxation Agreement between South Africa and United Arab Emirates

South Africa (“SA”) and the United Arab Emirates (“UAE”) had entered into a Double Taxation Agreement (“DTA”) on 23 November 2016. The provisions of the DTA are applicable from 1 January 2017. Generally, there are no taxes levied by the federal government in the UAE on the income or wealth of individuals and companies, except for oil and gas exploration companies, production companies and branches of foreign banks. In this regard, the tax rate in respect of oil and gas exploration companies varies between 55% and 85%.

2017 - 08 Feb 2017

PKF Managers Conference 2017

The 2017 Managers Conference was held at Spier Estate in Cape Town from 3 – 5 February.

2017 - 03 Feb 2017

CEO Message: Tone from the top – Volume 1

For our firm to have a good ethics and compliance programme we need to concentrate on the following:

2016 - 31 Jan 2017


A Special Voluntary Disclosure Programme has been introduced to allow South Africans to regularise any undisclosed foreign assets, the programme will run for a period of 11 months commencing on 1 October 2016 and ending on 31 August 2017. The legislation in this regard had been finalised by parliament on 16 December 2016 and was promulgated on 19 January 2017.

2016 - 13 Dec 2016

Partners Conference 2016

PKF SA held its annual national partners conference during the last weekend of November 2016 at the Mount Grace Hotel in the Magaliesberg. The partners were treated to a day’s training session on practice management by the UK’s Mark Lloydbottom, as well as an economic update by Efficient Group Director and Chief Economist, Dawie Roodt, on the Saturday morning.

2016 - 08 Dec 2016

Asset-for-share transactions: Tax Free Restructure

The Income Tax Act, 58 of 1962, contains several so-called ‘group relief’ provisions in terms whereof corporate restructures can take place on a tax neutral basis. One of these is if a transaction comprises an ‘asset-for-share transaction’, or put simply: where a company purchases an asset in exchange for which that company agrees to issue shares to the seller.

2016 - 08 Dec 2016

New Transfer Pricing Documents Required

The transfer pricing regime in the Income Tax Act, 58 of 1962, is regulated by section 31 of that Act. It in essence requires that cross-border transactions be entered into on an arm’s length basis where connected persons transact with one another. The obvious mischief sought to be countered is for connected persons to charge fees between one another to ensure that the party in the most tax beneficial regime is more profitable than the taxpayer in the more onerous tax jurisdiction.

2016 - 08 Dec 2016

Offshore companies and doing business in South Africa - A Companies Act Perspective

According to the most recent statistics released by the South African Revenue Service, South Africa remains a net importer of goods and services. Put differently, one could say that South Africans are more often clients in cross-border transactions than they would be the service provider. Many of our clients operate in this space, including foreign incorporated companies which are doing business in South Africa. This article is aimed at those specific clients of ours: those clients doing business in South Africa through companies incorporated outside of South Africa.

2016 - 08 Dec 2016

Tax Implications for International Branches

Irrespective of whether a South African company is expanding its business offshore, or whether international businesses set up shop in South Africa, companies trading internationally are often confronted with the complex tax implications for doing so. This article explores the tax implications linked to international branches of a company specifically; it does not consider the scenario where a corporate group would operate through separate companies set up in each of the various jurisdictions in which it operates. With a branch, it is contemplated therefore that a company tax resident in one country carries on operations in another country either by selling trading stock in that other country or rendering services there.

2016 - 12 Sep 2016


As you will recall in the Budget Speech the Minister of Finance proposed a Special Voluntary Disclosure Programme (SVDP) to enable South African resident to regularise foreign exchange transactions and the income tax consequences arising therefrom.

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