Budget changes the taxation of cross-border transactions

By Peter Dachs, Edward Nathan Sonnenbergs

The 2011 budget – the latest annual statement by the South African minister of finance about the nation’s finances – contained some interesting proposals relating to the taxation of cross-border transactions.

Peter Dachs 税务部联席主管 Co-head of tax department Edward Nathan Sonnenbergs
Peter Dachs
Co-head of tax department
Edward Nathan Sonnenbergs

It stated that a new dividends tax would replace the secondary tax on companies (STC) from 1 April 2012. Any dividend paid by South African-resident companies and any dividend paid by non-resident companies in respect of listed shares on or after 1 April 2012 will be subject to the dividends tax.

A foreign dividend paid in respect of unlisted shares will thus not be subject to the dividends tax. Such foreign dividends will therefore be subject to normal tax.

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Peter Dachs is co-head of the tax department at Edward Nathan Sonnenbergs

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