Comments on: Economic and political brics and choirs https://twentythirdfloor.co.za/2011/04/14/economic-and-political-brics-and-choirs/ Perspectives Fri, 22 Apr 2011 13:10:20 +0000 hourly 1 https://wordpress.org/?v=6.9.1 By: Andrew https://twentythirdfloor.co.za/2011/04/14/economic-and-political-brics-and-choirs/comment-page-1/#comment-16531 Fri, 22 Apr 2011 13:10:20 +0000 http://twentythirdfloor.co.za/?p=1062#comment-16531 (The carve-outs to which I’m referring above are carve-outs/exclusions from South African domestic taxation: income tax and, at least initially, STC. Interest and dividends are financial services and VAT exempt. Royalty income (supply) is, IIRC, located where the rights are exercised, which would be outside ZA if the rights are exercised outside of ZA.)

]]> By: Andrew https://twentythirdfloor.co.za/2011/04/14/economic-and-political-brics-and-choirs/comment-page-1/#comment-16530 Fri, 22 Apr 2011 13:08:01 +0000 http://twentythirdfloor.co.za/?p=1062#comment-16530 Don’t know if you’re aware, but we’ve recently been structuring a system that allows for our country to be used as a staging point for investment into Africa.

Our tax regime now includes an intermediary holding company structure that is engineered to allow us to be used as a treaty shopping destination – the entity is treated as tax resident, with carve-outs only for certain passive income (interest, dividends, royalties) related to substantial investments.

There’s still edginess around the ExCon issues – there was a requirement for annual approval that one was permitted to actively reinvest “on demand” into foreign investments. (Think of a private equity fund and draw-downs.) I haven’t been following as closely as I ought, so I’m not sure how this latter issue has played out.

]]> By: David Kirk https://twentythirdfloor.co.za/2011/04/14/economic-and-political-brics-and-choirs/comment-page-1/#comment-16508 Sun, 17 Apr 2011 09:51:24 +0000 http://twentythirdfloor.co.za/?p=1062#comment-16508 In reply to James Thorpe.

and our lobbying for our African neighbours to do the same…?

]]> By: James Thorpe https://twentythirdfloor.co.za/2011/04/14/economic-and-political-brics-and-choirs/comment-page-1/#comment-16507 Fri, 15 Apr 2011 07:43:44 +0000 http://twentythirdfloor.co.za/?p=1062#comment-16507 Maybe easy access to our mineral resources will help us remain part of the club.

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