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South Africa Issues Draft Notice on Adding Technical, Managerial or Consultancy Services as Reportable Arrangements

25 June 2015

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Proposed Changes

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South Africa

On 19 June 2015, the South African Revenue Service issued a Draft Public Notice on additional reportable arrangements for comment. The notice proposes that the rendering of technical, managerial or consultancy services by a non-resident to a South African resident be considered a reportable arrangement under certain conditions, including: When the non-resident, or its non-resident employees, agents, or representatives were physically present in South Africa or will be for the purpose of rendering such services; and The expenditure in respect of those services exceeds or will exceed ZAR 10 million (~USD 823,000) in aggregate For such services, the arrangements must...