South Africa Tax Agency Clarifies Tax Implications for Employer Companies of Proposed Share Incentive Regime

The South African Revenue Service Nov. 20 issued Binding Class Ruling No. BCR 091, clarifying the income tax and securities transfer tax implications for employer companies of a proposed share incentive scheme. The taxpayer, a resident wholly-owned subsidiary of an unspecified holding company, was an employer company within a group of companies and the administrator of the holding company’s share incentive programs. The primary purpose of the proposed share incentive program was to protect and enhance the businesses and incomes of the specified employer companies through incentivizing eligible employees to be efficient, be productive, and stay in the group’s employ. ...