Tax cases
Mobile Telephone Networks (Pty) Ltd (hereinafter “MTN”) v Commissioner for the South African Revenue Service (hereinafter “SARS”) (Case no 855/2021) [2022] ZASCA 142 (24 October 2021)
Alert 62
In this week's alert:
- Tax cases
- BPR 387: Attribution of Nett Income to a public benefit organisation
- VAT Connect Newsletter: Issue 15 (December 2022)
- BCR 84 – Transfer of funds held in trust to a ‘beneficiary fund’
- IN 126 – Extraordinary dividends treated as income or proceeds on the disposal of shares
- Tax cases
- BPR 387: Attribution of Nett Income to a public benefit organisation
- VAT Connect Newsletter: Issue 15 (December 2022)
- BCR 84 – Transfer of funds held in trust to a ‘beneficiary fund’
- IN 126 – Extraordinary dividends treated as income or proceeds on the disposal of shares
BPR 387: Attribution of Nett Income
SARS has published Binding Private Ruling (“BPR”) 387 which determines the tax consequences of a public benefit organisation holding a participatory interest in a controlled foreign company, which is a foreign incorporated charity.
VAT Connect Newsletter: Issue 15 (December 2022)
The latest VAT Connect Newsletter was released following the recent publication of the tax bills on 26 October 2022
BCR 84 – Transfer of funds held in trust
SARS has published binding class ruling (“BCR”) 84 which determines that tax consequences of the transfer of assets of a vesting trust to a “beneficiary fund”.
IN 126 – Dividends treated as income or proceeds
SARS issued Interpretation Note (“IN”) 126 to provide guidance on the interpretation and application of section 22B of the Income Tax Act 58 of 1962 (“IT Act”) and paragraph 43A of the Eighth Schedule thereto relating to the income tax treatment of extraordinary dividends on certain disposals and deemed disposals of shares by a company to prevent so-called “dividend stripping ”.