It’s a wrap folks!

As savour down the last few days of 2023, let’s take a moment to reflect on what’s happened this year.

Definitely one of the major South African tax news stories this year was the Coronation case, which set a few hearts a-flutter around the implications of outsourcing primary business activities as a controlled foreign company (“CFC”).  And as anticipated, the South African TLAB addressed the case by stipulating that outsourcing of primary functions would only be allowed by a foreign business establishment if it is outsourced to another CFC within the same country as the first CFC.  More to come on this no doubt.

Further changes on the African continent included Kenya revamping its VAT rules for imported services and unveiling new transfer pricing rules which included broadening the scope of transactions subject to a transfer pricing review.

Of course other notable mentions include Bermuda’s announcement of the introduction of corporate tax aligned with Pillar Two, the introduction of 9% corporate tax in the UAE (subject to various requirements) and the sun setting on Portugal’s popular non-habitual resident regime.

Lastly, towards the end of 2023, an interesting court case unfolded in Mauritius – the Alteo Energy case, where the Assessment Review Committee (ARC) ruled against the taxpayer, stating they could not benefit from the 3% partial exemption regime for interest income as it was not earned as a result of the taxpayer’s core income-generating activity. Following this decision, the taxpayer lodged an appeal with the Supreme Court of Mauritius, a development we’ll be closely monitoring in 2024 so stay tuned!

And tax news apart, what a year of growth it has been for the RvR team! We’ve welcomed numerous additions to our International Tax, Mauritian, South African Corporate, and Transfer Pricing teams and have grown to know and love them all and fully inculcate in them our very own orange culture. Perhaps most excitingly, we’ve established a new entity in in Ireland, and appointed a Transfer Pricing director there, so we have big plans for 2024.

Our growth story wouldn’t be complete without acknowledging you – our valued clients and partners. At Regan van Rooy, we take pride in not only delivering high-quality services but also in building strong, trusting relationships with each of our clients and stakeholders. We extend our heartfelt thanks to each one of you for choosing us as your trusted tax advisor.

As we eagerly anticipate continuing our collaborative journey in 2024, we wish you a safe and happy holiday season and a peaceful new year!