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Governments are rewriting tax policy for the AI era, deploying digital taxes, tailored incentives and algorithmic enforcement that redefine where value is created
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Sponsored by Webber WentzelChanges 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.
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Sponsored by Garrigues PortugalA recent Portuguese Arbitration Court decision (Case 639/2017-T), dealing with the application of the exemption method to foreign-based liquidation proceeds for non-habitual tax residents serves as a good illustration of how this domestic exemption works.
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Sponsored by Dhruva AdvisorsThe Income-tax Act, 1961 was amended in 2012 such that non-resident taxpayers are not entitled to claim relief under a tax treaty unless they obtain a tax residency certificate (TRC) from their country of residence. But a recent court ruling has changed the situation.
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