In a binding private ruling, the South African Revenue Service (SARS) has concluded that a non-resident company, whose effective management is not in South Africa, does not constitute a permanent establishment (PE).
Unlock this article.
The content you are trying to view is exclusive to our subscribers.
Two months since EU political agreement on pillar two and few member states have made progress on new national laws, but the arrival of OECD technical guidance should quicken the pace. Ralph Cunningham reports.