South African residents pay tax on their foreign dividends. However, various exemptions apply. In particular, where a resident of South Africa holds at least 20% of the ordinary shares in the declaring company and various other conditions are met, the foreign dividends are exempt from tax in the hands of the South African resident recipient.
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Arindam Mitra and Robin Hart examine how aggregate TP rules clash with transaction-level customs rules, creating compliance risks and requiring granular, SKU-level pricing strategies
The OECD’s project was up for debate as Matt Williams spoke to ITR following BDO’s tax strategist survey, which uncovered increased complexity and costs among multinationals