Countering Harmful Tax Practices: BEPS Action 5 – Global Tax Update

Harmful tax practices (e.g., tax havens, preferential tax regimes, tax rulings) are characterised by the propensity to erode tax bases of other countries which allegedly leads to an undesirable race-to-the-bottom on taxation rates. Action 5 of the OECD Action Plan on Base Erosion and Profit Shifting (“BEPS”), therefore, addresses the detecting and coordinated countering of such harmful tax practices, with a renewed focus on transparency and substance requirements.
Background
In 1998, the OECD Committee on Fiscal […]

By |September 14th, 2015|

Protocol Amending Cyprus-South Africa Double Tax Agreement Signed

On April 1 2015 Cyprus and South Africa signed a protocol amending their existing double tax agreement, which was signed in 1997 and has been in force since December 8 1998.

The protocol amends the following areas of the 1997 agreement:

the definition of ‘residence’;
withholding taxes on dividends; and
the exchange of information.

However, the protocol does not change the highly beneficial arrangements regarding the taxation of capital gains.
Residence
The protocol aligns the definition of a ‘resident of a […]

By |September 3rd, 2015|

Taxing executives and professionals working offshore

Tax residency has become an increasingly contentious area of law for individuals living and working overseas as it becomes as an area of increased audit activity for the ATO.

This paper looks at the basic rules around income, fringe benefits and superannuation and the principles around tax residence in the light of recent decisions.
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Winner – EOWA Employer of Choice for Women Citation 2009, 2010, 2011 and 2012
Winner – ALB Gold Employer of Choice […]

By |September 1st, 2015|