Business Tax and Company Law Quarterly - AZ
- Value-added tax and corporate transactions : the dragons slumber : part 1
- Foreign Pension Schemes: There Be Dragons, And Some Confusion — Part 1
- VAT, Indemnity Payments and Capitec Bank: The Good, The Bad and The Ugly (Part 1)
- VAT and corporate transactions : the dragons slumber : part 2
- VAT and corporate transactions : the dragons slumber : part 2
- Democratic principles underpinning tax administration in SA
- The impact of business rescue on tax claims : does SARS enjoy a preference under s 135 of the Companies Act against a company in business-rescue proceedings?
- The Ladysmith case - lessons in tax avoidance
- Tax Residence of Mobile South Africans
- Thistle and Coronation: Can a Taxpayer Place Reliance on a Legal Opinion to Avoid or Reduce Penalties while at the Same Time Withholding Disclosure of the Opinion from SARS?
- Dissenting minority shareholders' appraisal rights : reappraising the appraisal remedy in section 164 of the Companies Act 71 2008
- Understatement Penalties Through the Cases
- The taxation of hedge funds : the cart before the horse
- Supreme Court of Appeal Refuses ‘Reverse’ Piercing of the Corporate Veil
- ‘Most Favoured Nation’ Dividends Tax Treatment: A Tough Call for Dutch and Swedish Shareholders in South African Companies?
- Whatever Happened to Hedge Funds?
- The Companies Second Amendment Act 17 of 2024: Ameliorating the Time-Barring Regime Under Sections 77 and 162 of the Companies Act
- The application of Section 19 and Paragraph 12a to the Settlement of Disputed Debts : a ‘concession or Compromise’ of Another Kind!
- Judicial Forays in Statutory Construction
- Tax Residence of Mobile South Africans
- Circular Cash Flows: A PRIMER
- Amalgamations and mergers : tax and legal comparisons and nuances
- Value-conscious tax administration by SARS
- Regulating schemes of arrangement under the new Companies Act 71 of 2008 : innovations in minority protection
- Legal Privilege Under s 42A of the Tax Administration Act Analysed
- Hidden Complexities in the Right of Recourse Between Co-debtors and Co-sureties
- The Misuse and Abuse of Section 80J of the Income Tax Act
- Unlocking the Beneficial Interest and Beneficial Ownership Quagmire
- Beneficial Ownership Disclosure and Trusts
- A Purposive Interpretation of the ‘Qualifying Purpose’ Exemption in Sections 8E and 8EA of the Income Tax Act
- Retrospective legislation : the Pienaar Brothers case
- No Boardroom, No Debate: RESOLVING THE TENSION BETWEEN ROUND-ROBIN RESOLUTIONS AND COMPANY LAW DEMOCRATIC PRINCIPLES
- Purpose Requirement of the GAAR: Rethinking The ‘Subjective’ vs ‘Objective’ Debate
- Sale of immovable property : selected transfer duty and value-added tax implications
- Restructuring companies via the corporate rules : tax methodology and analysis
- A Bird’s-Eye View of the Current State of the Law relating to the Interpretation of Contracts and the Slow Death of the Parol Evidence Rule
- Determining corporate residence - The concept of 'place of effective management' in a shifting domestic and international fiscal landscape
- Leasehold improvements - the VAT implications
- Foreign Pension Schemes: There Be Dragons, and Some Confusion: South African Members Qua Beneficiaries Have a Vested Right to the Income and Capital of the Foreign Pension Scheme (Trust) Ab Initio — Part 2
- The taxation of carried interest
- VAT Apportionment: BGR 16 and Distributions from Trusts
- The Tax Administration Act : What every corporate tax administrator should know (part 3) - the understatement penalty regime revisited
- Rethinking Incentives in Africa Due to Pillar 2
- Ring-fencing of assessed losses : do the rules limit the set-off from capital gains?
- The Tax Characterisation of 'Earn-Outs'
- Connected persons under paragraph (d)(iv) of the definition of ‘connected person’ in the Income Tax Act : interpretation Note 67 misses the mark?
- Foreign branches and VAT : eish!
- VAT : leases, lodging, sub-leases and purpose
- When statutes collide - The application of section 45 of the Companies Act to a bank under curatorship in terms of section 69 of the Banks Act
- VAT, Indemnity Payments and Capitec Bank: The Good, The Bad and The Ugly (Part 2)
- SARS — Stand in Line! How Tax Debts Rank in Business Rescue
- The Tax Administration Act : what every corporate tax administrator should know (part 2)
- VAT: An ‘Indemnity Payment’ Under a Contract of Insurance is the Same as an Indemnity/Guarantee Under a Contractual Relationship, Not!
- Continuation Funds: The New Dawn in Private Equity Fund Formation
- Amalgamation transactions unpacked
- Information-gathering by SARS under the TAA : trumping the taxpayer's right to tax finality
- Understatement penalties : SARS needs to provide clarity
- Asset-for-share Transactions: THE NUMBER-OF-SHARES CONUNDRUM*
- X (Pty) Ltd v CSARS : another ride on the substance-over-form rollercoaster?
- Taxation of trusts : continued application of the conduit-pipe principle?
- Naught for the taxpayer’s comfort : the decisions in Big G and Clicks concerning future expenditure claims under section 24c
- The Deferral of Unrealised Foreign Exchange Gains and Losses Rules, and the Applicability to Parties Other Than the Lender or Borrower
- Registration of foreign companies as external companies in South Africa : some practical considerations and challenges
- A cryptocurrency wallet : is it ‘relevant material’ for tax administration purposes?
- Dividend stripping and equity funding : limitations and restrictions
- Exploring sections 44 and 45 of the new Companies Act : the perils of providing financial assistance
- South Africa’s Ambiguous Exchange Control Climate
- Information-gathering by SARS under the TAA : trumping the taxpayer's right to tax finality - part II
- Reportable Arrangements Under the TAA: An Overview
- The right of a redeemable preference shareholder to enforce payment of the redemption amount : a nebulous right!
- ‘Dividend–stripping’ Complexities and the Interaction with the ‘Rollover’ Relief Provisions
- Going Concern(ed): Potential Challenges in Sale-Of-Business Transactions
- Regulation and control of business-rescue practitioners : is there a suitable legal framework
- Pre-production problems : is section 11A of the Income Tax Act a solution?
- Retrospective legislation : do taxpayers have any recourse?
- Can Directors in a Private Company have Weighted Voting Rights at Board Meetings?
- When bedfellows potentially conflict : the extent of a business-rescue practitioner’s duty and potential liability in terms of the companies and tax administration acts
- The Tax Administration Act : what every corporate tax administrator should know (part 1)
- Will the real NWK please stand up!
- Inter-vivos trusts and trustees revisited
- Realisation of secured immovable property in the winding-up of insolvent estates - does the mortgagee's secured claim to proceeds trump SARS's claim for CGT on the disposal?
- Dividends tax - 9 months down the line
- Partnerships / joint ventures and VAT - the knights and the dragons are confused
- Previewing the new Tax Administration Act : more muscle for SARS - taxpayers beware!
- VAT and Branches of Foreign Companies and the Case
- Issuing shares in exchange for a negotiable instrument or for future services - the tax dimension
- Company law in transition : from the familiar to the unknown
- The OECD Commentarie : on what legal basis and to what extent are they relevant to tax treaty interpretation?
- Interest-deduction limitation - Section 23M
- Leveraged FTC Generators : did the Davis Committee give them too much credit?
- Interest-free and low-interest shareholder loans
- Provision for doubtful debts : non-banks (more accounting influences)
- The Franchise Industry : a more complicated tax landscape than perceived at first glance
- VAT — A Tale of Two Supreme Court of Appeal Decisions:
- Tax consequences on disposal of shares held by a CFC
- Set–off : the old versus the new debt-reduction rules
- Non-executive directors and tax : SARS takes a stand
- ‘Foreign dividend’ and ‘foreign return of capital’ : a home-grown solution to their proper interpretation in section 1 of the Income Tax Act
- VAT and partnerships
- The retrospective operation of statutory amendments to taxation laws : interpreting the amendments to section 8EA of the TLAA, 2016