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SARS Clarifies Tax on Reinsurance Business Transfer to Nonresident Branch; Dividend and VAT Implications

  • SARS issued Binding Private Ruling No. BPR 416 on the tax treatment of a reinsurance business transfer.
  • Only the transfer of net assets to the permanent establishment (PE) is considered a dividend, unless from contributed tax capital.
  • The disposal of the private company’s enterprise is a zero-rated VAT supply.
  • The ruling applies to assessment years 2024 and 2025.

Source: news.bloombergtax.com

Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.



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