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By continuing to use our website, you agree to our use of such cookies.The South African Revenue Service (SARS) released Binding Private Ruling 210 (Ruling) on 11 November 2015.For further information contact David Reynolds , Rosey Blundell or Chris Williams .We use cookies to improve your user experience and measure the use of our website.

those where the main purpose is not for the avoidance of tax) should be unaffected.The TAAR may also catch ‘special purpose companies’ set up for individual contracts (as detailed above). Firstly, the TAAR will not apply to cases where the assets distributed represent irredeemable shares in a subsidiary of the company – this would apply in the case of certain non-tax neutral demergers (i.e.where a holding company is liquidated, the shares of its subsidiaries are distributed directly to the individual shareholders, and the shareholders are subject to capital gains tax on the value distributed).Secondly, the repayment of originally subscribed share capital is also excluded from the scope of the TAAR.There has been a lot of speculation that these provisions could apply to non-statutory demergers (i.e.

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