Webber Wentzel

South Africa's Supreme Court of Appeal (SCA) handed down an important judgment on the doctrine of simulation, or substance over form, on November 9 2018, putting to rest some significant confusion created by an earlier judgment of the Gauteng Tax Court.

Changes made last year to South Africa's dividend stripping rules have effectively eliminated the ability of group companies to make use of the rollover relief provisions that historically have allowed qualifying liquidations or deregistration of group companies (both local and foreign) to be done on a tax-neutral basis.

Proposed changes to the Income Tax Act, contained in the 2018 draft Taxation Laws Amendment Bill (DTLAB), were released for comment on July 16 2018. This update focuses on certain international tax-related proposals.