Tax Perils of Low-interest and Interest-free Loans

Author: Professor Jackie Arendse (University of the Witwatersrand) Loans between companies and shareholders are a fairly common feature on the corporate landscape. On the one hand these loans may form part of the financing structure of the company but the opposite could apply where a company advances a loan to a shareholder or perhaps another [...]

Guernsey Modifies ‘Zero/Ten’ Regime

by Jason Gorringe,, London Guernsey’s legislative assembly, the States of Guernsey, has unanimously approved a law that will repeal the island’s deemed distribution regime from January 1, 2013. The Income Tax (Zero 10) (Deemed Distributions) (Repeal) (Guernsey) Ordinance, 2012, provides for the repeal of the regime, which ensures that tax is paid on individuals’ [...]

New Companies Act won’t ease red tape burden for small firms

Issued by DUO Marketing + Communications on behalf of Idu Software South Africa’s new Companies Act aims to reduce the bureaucratic burden on small businesses – but, says Kevin Phillips of financial software developer idu Software, private sector business practices are likely to undermine some of the Act’s intentions. The promised gains are most likely [...]

Tax incentives for Regional Holding Companies in SA in the pipeline?

Anton Lockem, Shepstone & Wylie Lesley van Duffen A regional holding company (RHC) may be established for a number of reasons, most notably for economic participation and expansion within a region. A RHC serves as a gateway into other countries within a region. The decision of where to register a RHC is to a large [...]

Are your intentions no longer relevant?

Amanda Warner, International Tax Director, Ernst & Young Capitals gains and income are taxed at different rates. Whether or not one crosses the Rubicon from holding an asset as a capital asset or to holding it on revenue account, has long been subject to the scrutiny of our court. These cases generally focused on the [...]

Manuel calls shareholders to arms

By Rob Rose Business day Finance Minister Trevor Manuel said yesterday that shareholders were failing to call companies to account for poor corporate governance. Speaking at a Sanlam conference on shareholder activism, Manuel said that while shareholders had a right to oversee the affairs of a company, this right was “tragically too often ignored”. The [...]