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South Africa Adds To Reportable Arrangements

by Lorys Charalambous, Tax-News.com, Cyprus

23 June 2015


The South African Revenue Service (SARS) has issued for consultation a draft Public Notice to add to the list of reportable arrangements under the Tax Administration Act, 2011 (TAA).

The relevant section of the TAA provides that every company or trust which derives, or will derive, any tax benefit in terms of a reportable arrangement must report that arrangement to SARS within 60 days, so that the agency is able to evaluate it from an anti-avoidance point of view at an early stage of its implementation.

The TAA empowers SARS to add to the list of arrangements in subsequent Notices, where it identifies arrangements that could enable the avoidance or postponement of liability to taxes on income, or reduce that liability.

The new draft Notice adds any arrangement that involves an agreement for the provision of technical, managerial, or consultancy services by a non-resident person to a resident person where that non-resident person was, is, or expects to be physically present in South Africa "in connection with or for [the] purposes of rendering those services," where consideration for those services exceeds, or is anticipated to exceed, ZAR10m (USD822,000) in aggregate.

Comments on the draft Notice may be submitted to SARS by no later than June 30, 2015.

TAGS: South Africa | compliance | tax | business | tax compliance | tax authority | services | Africa | Tax

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