Business consulting services
Our business consulting services can help you improve your operational performance and productivity, adding value throughout your growth life cycle.
Business process solutions
We can help you identify, understand and manage potential risks to safeguard your business and comply with regulatory requirements.
Business risk services
The relationship between a company and its auditor has changed. Organisations must understand and manage risk and seek an appropriate balance between risk and opportunities.
As organisations become increasingly dependent on digital technology, the opportunities for cyber criminals continue to grow.
Forensic and investigation services
At Grant Thornton, we have a wealth of knowledge in forensic services and can support you with issues such as dispute resolution, fraud and insurance claims.
Mergers and acquisitions
Globalisation and company growth ambitions are driving an increase in M&A activity worldwide. We work with entrepreneurial businesses in the mid-market to help them assess the true commercial potential of their planned acquisition and understand how the purchase might serve their longer- term strategic goals.
Recovery and reorganisation
Workable solutions to maximise your value and deliver sustainable recovery
Transactional advisory services
We can support you throughout the transaction process – helping achieve the best possible outcome at the point of the transaction and in the longer term.
We provide a wide range of services to recovery and reorganisation professionals, companies and their stakeholders.
The International Financial Reporting Standards (IFRS) are a set of global accounting standards developed by the International Accounting Standards Board (IASB) for the preparation of public company financial statements. At Grant Thornton, our IFRS advisers can help you navigate the complexity of financial reporting from IFRS 1 to IFRS 17 and IAS 1 to IAS 41.
Audit quality monitoring
Having a robust process of quality control is one of the most effective ways to guarantee we deliver high-quality services to our clients.
Global audit technology
We apply our global audit methodology through an integrated set of software tools known as the Voyager suite.
Corporate and business tax
Our trusted teams can prepare corporate tax files and ruling requests, support you with deferrals, accounting procedures and legitimate tax benefits.
Direct international tax
Our teams have in-depth knowledge of the relationship between domestic and international tax laws.
Global mobility services
Through our global organisation of member firms, we support both companies and individuals, providing insightful solutions to minimise the tax burden for both parties.
Indirect international tax
Using our finely tuned local knowledge, teams from our global organisation of member firms help you understand and comply with often complex and time-consuming regulations.
Innovation and investment incentives
Dynamic businesses must continually innovate to maintain competitiveness, evolve and grow. Valuable tax reliefs are available to support innovative activities, irrespective of your tax profile.
Private client services
Our solutions include dealing with emigration and tax mitigation on the income and capital growth of overseas assets.
The laws surrounding transfer pricing are becoming ever more complex, as tax affairs of multinational companies are facing scrutiny from media, regulators and the public
Tax policies are constantly evolving and there are a number of complex changes on the horizon that could significantly affect your business.
Outsourcing Changes to the Outsourcing legislation, specifically when offshoringSignificant changes to the dynamic of the financial services sector in recent years have shifted the paradigms in how we work. The increased digitisation of the workforce, changes in business models, globalisation, and remote working capabilities have led to a new approach to the delivery of services.
Asset management Inflation and tax planningThe recent onset of rapid inflation is an unwelcome development that is having a widespread impact on US businesses and tax planning.
With many South African tax residents working abroad, recent changes to tax law on foreign employment income may see many taxpayer’s affairs increase in complexity and potentially, incur an additional tax charge.
The amendments to Section 10(1)(o)(ii) should be reviewed by individuals who have left South Africa to work overseas, are undertaking frequent business travel outside the country, and employers with internationally mobile employee populations. For multinationals with tax equalised employees, the tax cost of international assignments may increase from 2020 with the changes to the current exemption.
South Africa introduced a tax residence-based tax system with effect from 1 March 2001 meaning that South African tax residents are subject to tax on their worldwide income.
Individuals working outside South Africa have been able to rely on both domestic tax law and Double Taxation Agreements (DTAs) to prevent double taxation under certain conditions. Under South African tax law, Section 10(1)(o)(ii) provided an exemption that that prevents employment income being taxed both in South Africa and a foreign country where the individual is working, provided that certain conditions were met.
In the 2017 Budget Review, the National Treasury proposed that the exemption should be repealed on the basis it was deemed too generous to individuals and may generate fiscal loss to the government. The final proposal has not resulted in the total abolition of the exemption but does reduce its original scope.
Current application of Section 10(1)(o)(ii)
The section 10(1)(o)(ii) exemption currently allows for a South African tax resident’s employment income that relates to services physically rendered outside of South Africa to be exempt from tax provided the individual is rendering services for or on behalf of their employer outside South Africa:
- For a period exceeding 183 full calendar days, in aggregate, during any period of 12 months (commencing or ending during a year of assessment)
- In the same 12-month period, must be outside South Africa for a continuous period exceeding 60 full calendar days.
Where an individual qualifies for the exemption, all remuneration earned in relation to the foreign employment duties will be exempt from tax in South Africa.
Future application of Section 10(1)(o)(ii) and double taxation mechanisms
Effective from 1 March 2020 (2021 South African tax year), the Section 10(1)(o)(ii) exemption will be limited to ZAR 1 million for the year of assessment.
For individuals whose income exceeds this threshold, further relief may be available on income more than ZAR 1 million (approximately USD 72,250) are as follows:
- Relief under a DTA where the taxpayer may not be taxable in South Africa on certain foreign sourced income
- Claiming a foreign tax credit in respect of taxes paid in the foreign country on their foreign sourced income also subject to South African tax.
Where there is no DTA in place (or the DTA does not grant exclusive taxing rights to one of the states), South African tax residents will look to claim foreign tax credits. Taxpayers in low or no tax locations, such as Singapore and Dubai, may however find they will have residual South African tax liabilities from 2020.
We hope that the information outlined in this update will help you navigate the changing rules. Claiming foreign tax credits can be complex and taxpayers will need to understand the implications and potential future exposure. If you would like to discuss in further detail, please get in touch with Veli Ntombela, Grant Thornton South Africa or your local member firm.
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