n Tax Breaks Newsletter - Defining 'listed shares' for purposes of the foreign dividend exemption : advance tax rulings

Volume 2014, Issue 339
  • ISSN :



The factual circumstances in respect of which the ruling was made are as follows: Company Y is a company incorporated and resident in foreign country Y. Company X is a companyincorporated and resident in country X. Company X is also a wholly-owned subsidiary of Company Y. Company X is to be listed on the JSE Limited. Its business is investment in foreign debt instruments, on which it will receive interest returns. Company X intends to raise funds for its business by issuing certain preferred securities. The preferred securities will be issued through its branch in country Y, and would be redeemable after five years or more at the same amount paid for them; confer preferred rights to dividends; generally not carry any voting rights; rank with all other preferred securities; and rank in preference to ordinary shares.

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