21 January 2019

South Africa enacts tax amendment bills

On 17 January 2019, the Taxation Laws Amendment Bill1 and the Tax Administration Laws Amendment Bill2 (which were introduced by South Africa’s Minister of Finance into Parliament on 24 October 2018) were promulgated as Acts of Parliament.3

The amendments now enacted cover, among others:

  • Addressing anomalies in respect of medical tax credits
  • Amendments to the debt restructure rules
  • Amendments to the dividend stripping anti-avoidance rules regarding preference shares
  • Amendments to the interaction between the dividend stripping anti-avoidance rules and the corporate reorganization rules
  • Amendments to the rules for debt-financed acquisitions of a controlling interest in an operating company
  • Amendments to the doubtful debt allowance
  • The introduction of new rules to address the use of foreign trusts to avoid tax in respect of controlled foreign companies
  • Extension of the Employment Tax Incentive
  • Addressing tax avoidance through the use of collateral arrangements
  • Review of venture capital rules
  • Review of international shipping rules

Endnotes

1. B38 -2018.

2. B39 -2018.

3. Taxation Laws Amendment Act No 23 of 2018 and Tax Administration Laws Amendment Act No 22 of 2018.

For additional information with respect to this Alert, please contact the following:

Ernst & Young Advisory Services (Pty) Ltd., Johannesburg
  • Brigitte Keirby-Smith | brigitte.keirbysmith@za.ey.com
Ernst & Young Advisory Services (Pty) Ltd., Cape Town
  • Ide Louw | ide.louw@za.ey.com
Ernst & Young Advisory Services (Pty) Ltd., Durban
  • Candice Van Den Berg | candice.vandenberg@za.ey.com
Ernst & Young LLP (United Kingdom), Pan African Tax Desk, London
  • Rendani Neluvhalani | rendani.mabel.neluvhalani@uk.ey.com
  • Byron Thomas | bthomas4@uk.ey.com
Ernst & Young LLP, Pan African Tax Desk, New York
  • Dele A. Olaogun | dele.olaogun@ey.com

ATTACHMENT

Document ID: 2019-5091