n Without Prejudice - Tax uncertainty the poison pill for foreign investors : tax

Volume 11, Issue 8
  • ISSN : 1681-178X



On June 2 this year, National Treasury and SARS released a drastic proposal in the form of the Draft Taxation Laws Amendment Bills, 2011 (the Draft Bills), wholly suspending the intra-group relief afforded in terms of s45 of the Income Tax Act (58 of 1962) with immediate effect. In the tumultuous months since, the Treasury and SARS have had the opportunity to consult with many affected parties resulting in a revised short-term approach proposed in the Draft Guide on the Disclosure of Reorganisation Transactions (the Draft Guide) and a Background Note, released on August 12 and August 3 respectively.

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