MIND THE WITH KPMG S 2015/6 BUDGET WATC H GAP. Tax Reference Guide. kpmg.co.za

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1 MIND THE 2015/6 BUDGET WATC H WITH KPMG S GAP Tax Reference Guide kpmg.co.za

2 2015 KPMG Services Proprietary Limited, a South African company and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative African Tax Solution Centre Yes, we have tax experts on the ground servicing 54 countries through our 33 dedicated tax offices. But it is not only about having a fantastic footprint in Africa. These days you need solutions that resolve the complexity and challenges in operating ACROSS Africa. The KPMG Africa Tax Solution Centre proactively builds solutions to increase your competitiveness and profitability. For advice on how to navigate the diverse and complex operating environment, contact us at africantaxsolution@kpmg.com ( KPMG International ), a Swiss entity. All rights reserved. MC12191

3 INCOME TAX: Individuals and Trusts Tax Rates (year of assessment ending 29 February 2016) Taxable income Rates of tax R R R R % of each % of the amount above % of the amount above % of the amount above % of the amount above and above % of the amount above Tax Thresholds Age Threshold (R) Below age Age 65 to below Age 75 and over Trusts, other than special trusts, will be taxed at a flat rate of 41%. Tax Rebates Primary rebate for natural persons R Secondary rebate for natural persons aged 65 and older R Tertiary rebate for natural persons aged 75 and older R

4 Allowance Subsistence Allowances and Advances Where the recipient is obliged to spend at least one night away from his/her usual place of residence on business and the accommodation to which that allowance or advance relates is in South Africa and the allowance or advance is granted to pay for: Meals and incidental costs, an amount of R 353 per day is deemed to have been expended Incidental costs only, an amount of R 109 for each day which falls within the period is deemed to have been expended. For overseas costs the applicable rate per country is available on the SARS website. Travel Allowance A log book confirming business kilometres travelled must be maintained in order to claim any deduction for business kilometres. PAYE must be withheld by the employer on 80% of the allowance granted to the employee. The percentage may be reduced to 20% PAYE withholding if the employer is satisfied that at least 80% of the use of the motor vehicle for the tax year will be for business purposes. Where the employee has borne the full cost of licence, insurance, maintenance and fuel, the employee may claim a deduction at the time of preparing his/her income tax return for business kilometres travelled and will be taxed on the portion of the allowance not claimed as a deduction. Where the distance travelled for business purposes does not exceed kilometres per annum, no tax is payable on an allowance paid by an employer to an employee up to the rate of 318 cents per kilometre, regardless of the value of the vehicle. This alternative is not available if other compensation in the form of an allowance or reimbursements is received from the employer in respect of the vehicle. 2

5 If you want to be part of the most sought-after tax professional group in the country, you should be with the best. KPMG is ranked South Africa s top employer for business students in Universum s World s Most Attractive Employer survey for 2012 and For further information, contact us at taxandlegal@kpmg.co.za kpmg.co.za 2015 KPMG Services Proprietary Limited, a South African company and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative ( KPMG International ), a Swiss entity. All rights reserved. KPMG and the KPMG logo are registered trademarks of KPMG International Cooperative ( KPMG International ), a Swiss entity. MC12873

6 Travel Table Rates per kilometre which may be used in determining the allowable deduction for business-travel, where no records of actual costs are kept: Value of the vehicle (including VAT) (R) Fixed cost (R/p.a) Fuel cost (c/km) Maintenance cost (c/km) exceeding Fringe benefits Company Car / Employer Owned Vehicles The monthly taxable value of a company car acquired in any way other than under an operating lease (as defined) is 3.5% of the determined value of each vehicle. If the vehicle is subject to a maintenance plan, this amount is reduced to an amount equal to 3.25% of the determined value of vehicle. Depending on the manner in which the vehicle is acquired, the determined value is equal to the original cost to employer of purchasing the vehicle (including VAT), cash value of the vehicle, the retail market value or the market value of the vehicle at the time when the employer first obtained the vehicle or the right of use of that vehicle. 4

7 NOTE: From 1 March 2015, the determined value of vehicles acquired, in any manner other than under an operating lease (as defined), on or after that date, will be the retail market value of such vehicle as determined by the Minister by Regulation. If the vehicle was acquired under an operating lease (as defined) the monthly taxable value is equal to the actual cost to the employer incurred under that operating lease and the cost of fuel in respect of that vehicle. 80% of the taxable benefit will be subject to PAYE on a monthly basis. The percentage may be reduced to 20% if the employer is satisfied that at least 80% of the use of the company car for the tax year will be for business purposes. The taxable value may be reduced on assessment of the employee s income tax return in accordance with the ratio of business kilometres travelled to total kilometres travelled. Further relief is available for the cost of licence, insurance, maintenance and fuel for private travel if the full cost was borne by the employee and the number of private kilometres travelled is substantiated by a log book. Employer provided residential accommodation A taxable fringe benefit arises where an employer provides an employee with residential accommodation either free of charge, or for a consideration which is less than the rental value. The value of the benefit is, where the accommodation is owned by the employer or by an associated institution in relation to the employer, calculated with reference to a prescribed formula. NOTE: From 1 March 2015, where the employer-provided accommodation is leased by the employer from an unconnected third party, the taxable value will be equal to the lower of the cost to the employer in providing the accommodation and the amount calculated with reference to the formula. 5

8 Exemptions (individuals) Local interest and dividend income Under 65 years of age The first R of interest income is exempt. Over 65 years of age The first R of interest income is exempt. Interest is exempt where earned by non-residents who are physically present in South Africa for less than 183 days in aggregate during the twelve-month period preceding the date on which the interest is received by or accrued to that person. Also refer to the section on Tax Free Investments. South African dividends are exempt after the withholding of dividends tax. Foreign interest and dividends There is no exemption in respect of foreign interest. Where an individual holds less than 10% of the equity share capital of a foreign company, which distributes a dividend, the dividend will be taxed at a maximum effective rate of 15% as determined by a formula. Deductions from Income Current Pension Fund Contributions The deductible amount is the greater of: (1) 7.5% of remuneration from retirement funding employment, or (2) R Any excess may not be carried forward to the following year of assessment. 6

9 Arrear Pension Fund Contributions Maximum of R per annum. Any excess over R1 800 may be carried forward to the following year of assessment. Current Retirement Annuity Fund contributions The deductible amount is the greater of: (1) 15 % of taxable income other than from retirement funding employment, or (2) R less current deductions to a pension fund, or (3) R Any excess may be carried forward to the following year of assessment Arrear Retirement Annuity Fund contributions Maximum of R1 800 per annum. Any excess over R1 800 may be carried forward to the following year of assessment. Donations to certain Public Benefit Organisations The deduction is limited to 10% of taxable income before deducting medical expenses and donations. NOTE: From 1 March 2014 and in respect of any donations made on or after that date, any amount not allowed as a deduction solely by reason of the fact that the donation exceeded the maximum amount deductible may be carried forward to the following year of assessment. Retirement and Savings Reforms Contributions to Pension, Provident and Retirement Annuity Funds In 2013, new provisions with regard to retirement fund contributions were introduced into the Income Tax Act and were expected to come into effect on 1 March However, National Treasury and SARS have announced that the 7

10 implementation date of retirement reform has been postponed to 1 March From the implementation date, employer contributions to retirement funds on behalf of employees will be deemed to be a taxable fringe benefit in the hands of the employees. Individuals will be allowed to deduct up to 27.5% of the greater of taxable income or remuneration for contributions made to approved pension, provident and retirement annuity funds. The maximum deduction will be capped at R per annum. Any contributions in excess of the percentage/monetary cap will be carried forward and available for deduction in future tax years. Tax Free Investments Tax free savings and investment accounts were introduced to promote retirement savings and support long term economic growth. All returns received from tax free savings and investment accounts, such as interest, dividends and capital gains will be 100% tax free, from 1 March 2015 onwards. A tax free investment is defined as a financial instrument or long term insurance policy, owned by a natural person and administered by a person or entity as designated by notice in the Government Gazette, by the Minister of Finance. An annual contribution limit of R cash and a lifetime contribution limit of R will apply. Currently, only new contributions will be considered as existing investor products cannot be converted or reclassified into a tax free saving and investment account (this may change in future). All proceeds received from a tax free investment and capitalised, as well as the transfer between tax free investment accounts, shall not be taken into account when determining whether a person exceeded the annual or lifetime contribution limits. Please note that transfers of tax free savings accounts will be postponed to 1 March

11 It is important to note that harsh penalties apply, if during any year of assessment a person contributes amounts in excess of the contribution limits, as the person will be required to pay an amount of normal tax equal to 40% of the excess amount contributed (regardless of whether the person is at the maximum marginal rate of tax). Further regulations have been made by the Minister, which prescribes requirements to which financial products must conform, as well as, requirements for the disclosure and transfer of a tax free investment. Medical and disability expenses Medical scheme fees tax credit Taxpayers may deduct from their tax liability a tax credit of R270 for the first two beneficiaries and R181 for each additional beneficiary, in respect of medical aid contributions. Additional medical expense deduction Taxpayers under the age of 65 years may deduct an additional tax credit equal to 25% of (1) medical aid contributions in excess of four times the total allowable medical scheme fees tax credits (2) plus qualifying medical expenses (3) which exceeds 7.5% of the person s taxable income (excluding any retirement fund lump sum benefit, retirement fund lump sum withdrawal benefit and severance benefit). Taxpayers 65 years and older and those with disabilities or with disabled dependents may deduct an additional tax credit equal to (1) 33.3% of medical aid contributions in excess of three times the total allowable medical scheme fees tax credit (2) plus 33.3% of qualifying medical expenses. 9

12 Taxation of lump sum benefits Retirement and severance benefits The tax-free lump sum benefit upon retirement and in respect of severance benefits is R The rates for the taxation of lump sums upon retirement and in respect of severance benefits are set out below: Taxable income Rates of tax R R R R % of amount % of the amount above % of the amount above and above % of the amount above Retirement fund lump sum benefits consist of lump sums from a retirement fund on death, retirement or termination of employment due to redundancy or termination of the employer s trade. Severance benefits consist of lump sums from or by arrangement with an employer due to termination of a person s office or employment in certain circumstances. 10

13 Taxation of lump sum benefits upon withdrawal from a retirement fund Taxable income Rates of tax R R R R % of amount % of the amount above % of the amount above and above % of the amount above Payroll Taxes and Levies: PAYE, UIF and SDL Pay-as-you-earn ( PAYE ) Employers are required to withhold PAYE from remuneration paid to employees. The PAYE must be paid to SARS by the 7th day of the month following the month in which the remuneration is received. If the 7th falls on a weekend or public holiday, the payment must be made by the last business day before the 7th. Skills Development Levy ( SDL ) Employers with a payroll of more than R per annum must account for SDL, at a rate of 1% of total remuneration paid to employees. Unemployment Insurance Fund Contributions ( UIF ) UIF contributions are payable by employers to SARS on a monthly basis and are calculated at a rate of 2% of remuneration paid or payable to each employee during the month, up to a maximum remuneration threshold of R per month or R per annum. NOTE: It has been proposed that the maximum remuneration threshold should be reduced to R per month for the 11

14 2015/16 tax year. This means that employers and employees will each pay R 10 a month, since both the employer and the employee are required to make a contribution of 1% each of the employee s remuneration (up to the threshold) on a monthly basis (i.e. a total of 2%). Employment Tax Incentive ( ETI ) The ETI was introduced in 2014 to encourage youth employment. This is done by way of reducing the employer s PAYE liability, by way of an incentive, in respect of qualifying employees (i.e. employees between the ages of 18 and 30 years that receive monthly remuneration between R2 000 or the relevant minimum wage and R6 000). The maximum amount of the incentive that can be claimed per qualifying employee for the first twelve months is R and thereafter R 500 for the next twelve months. Legislation has been introduced from 1 March 2015, to simplify the calculation of the employment tax incentive and provide clarity for employers who have employees that work for part of a month. Where a qualifying employee works more than 160 hours a month, the actual value of remuneration is used to calculate the incentive amount. Where a qualifying employee works for part of a month, the gross up is no longer calculated by using a discretionary full time calculation but rather linked to a baseline of 160 hours of work per month. Amendments have also been made to the reimbursement mechanism. The excess amounts available for roll over at the end of the bi-annual employer reporting period, will be ring fenced and can only be claimed after SARS has verified that the employer is tax compliant. If the employer is not tax compliant, the excess amount will be reimbursed when the employer becomes tax compliant. However, from 1 January 2014, should the employer fail to become tax compliant within the next six months, the excess amount will be lost and the rolled over amount will be reset to zero. 12

15 Corporate Taxpayers Corporate Tax Rates Type Rates of Tax 2015/16 Companies Resident company 28% Non-resident company 28% Personal Service Provider 28% Company Gold mining, oil & gas, and long-term insurance companies are subject to special rules and tax rates Small Business Corporations R0 R % R R % of the amount above R R R R % of the amount above R R and above R % of the amount above R Micro Businesses 1 R0 R % R R % of the amount above R R R R % of the amount above R R and above R % of the amount above R Micro businesses have the option of making payments for turnover tax, VAT and employees tax at twice yearly intervals. 13

16 Incentives R10.2 billion has been allocated over the MTEF period to manufacturing development incentives and support for growing service industries, such as business process outsourcing. In his budget, Nhlanhla Nene has indicated that the manufacturing competitiveness enhancement programme will spend R5.4 billion and will assist companies with financial support to upgrade facilities and skills development. Special economic zones are allocated R3.5 billion over the medium term, mainly for infrastructure development. The energy-efficiency savings tax incentive will be increased from 45 c/kwh to 95 c/kwh and will be extended to cogeneration projects to encourage firms to support a greener economy. Other measures under consideration include enhancing the accelerated depreciation for solar photovoltaic renewable energy. In addition, it is still envisaged that the carbon tax will be introduced in 2016, however, its administration will be dealt with under the Customs Act. Some proposed amendments which will be considered for the 2015 taxation laws amendment cycle include: Extension of the window period for the industrial policy project incentive (section 12I) to 31 December 2017 Possible expansion of the UDZ demarcation areas referred to in section 13quat of the Income Tax Act Measures to address backlogs in the adjudication process in relation to R&D applications Government will review the tax treatment of government grants to remove unintended anomalies arising before and after the introduction of section 12P of the Income Tax Act, as well as the regulatory mechanism relating to these grants 14

17 Some amendments around the ability of a company situated in a SEZ to qualify for the reduced tax rate in terms of section 12R of the Income Tax Act will also be considered Employee Share Schemes The taxation of equity instruments acquired by employees or directors by virtue of their employment or position as director is primarily governed by the provisions of section 8C of the Income Tax Act. The interrelationship between section 8C and other sections of the Income Tax Act relating to employee share schemes will be reviewed. Withholding taxes Type Withholding Taxes Dividends 15% Interest paid to non-residents 15% Royalties paid to non-residents 15% Service fees paid to nonresidents - Amounts paid to non-resident 15% entertainers and sportspersons Disposal of fixed property by non-residents Rates of Tax 2015/16 Individuals: 5% Companies: 7.5% Trusts: 10% The rates below may be reduced by the provisions of a relevant Double Tax Agreement ( DTA ). It is no longer necessary to obtain SARS approval to qualify for a reduced rate under an applicable DTA. Rather the foreign recipient of the Royalty or the 15

18 Interest should provide a declaration to the payor confirming that the DTA rate applies. SARS has released the prescribed form pertaining to the declaration for interest withholding tax. Dividends Dividends tax is a final tax levied at a rate of 15%. The tax is levied on the dividends paid by a resident company and by a nonresident company in respect of shares listed on the JSE. Royalties Royalty withholding tax is a final tax. The rate was increased from 12% to 15% with effect from 1 January The withholding tax is levied on the gross amount of royalties paid to a non-resident, where the royalty is of a South African source. Interest Interest withholding tax is a final tax that will be levied at a rate of 15% effective from 1 March The withholding tax will be levied on interest paid to a non-resident where the interest is of a South African source. It is proposed that the definition of interest be defined for purposes of the withholding tax. Service fees Services fees withholding tax is a final tax that will be levied at a rate of 15% effective from 1 January The withholding tax will be levied on service fees paid to a non-resident, where the service fee is of a South African source. Disposal of immovable property by non-residents Tax is withheld on behalf of non-resident sellers of immovable property (including interests in immovable property, eg property rich companies) in South Africa, which tax can be set off against the normal tax liability of the non-residents. The definition of immovable property will be defined to align with the OECD definition relating to the right to work mineral deposits. 16

19 International Tax Base Erosion and Profit Sharing: Transfer Pricing The Minister announced that government will propose amendments to improve transfer pricing documentation and reporting, and change the rules for controlled foreign companies and the digital economy. To counter base erosion and profit shifting, the Minister announced that the provisions relating to the capital gains tax on the cross-issue of shares may be relaxed in order to be more accommodating to legitimate commercial transactions. Furthermore, it is proposed that the diversionary rule relating to the sale of goods by a CFC to a South African resident connected person be reinstated to more effectively address the taxing of profits from such transactions. Foreign Tax Credits It has been proposed that the foreign tax credits available in section 6quin be withdrawn. Customs and Excise Specific customs and excise duties With effect from 25 February 2015 specific customs and excise duties are increased. Most alcoholic beverages increased between 4.8% and 8.5% (excluding traditional African beer and beer powder which remain unchanged). Tobacco products and cigars increased between 5% and 7%. Ad valorem excise duties From 1 April 2015, the 7% ad valorem excise duty on digital cinema projectors of a value exceeding R is abolished. General Fuel Levy and Road Accident Fund Levy The General Fuel Levy for 2015/2016 is increased by 30.5c/ li to 255c/li and 240c/li for petrol and diesel, respectively. The Road Accident Fund Levy will increase by 50c/li to 154c/li. Both increases will take effect on 1 April

20 Environmental Tax Tyre Levy It is proposed that a new tyre levy is introduced with effect from the last quarter of 2015, which will be administered through the Customs and Excise Act. The levy will replace the existing levy administered by the Department of Environmental Affairs. Electricity Levy Government is considering increasing the environmental levy by 2c/kWh to 5.5c/kWh. 18

21 Capital Gains Tax Effective CGT rates Type of taxpayer Individuals and Special Trusts Inclusion Rate Statutory Rate Effective Rate 33.3% 0% 41% 0% 13.65% Other Trusts 66.6% 41% 27.31% Companies (including personal service provider companies and branches of nonresident companies) 66.6% 28% 18.65% Small business corporations 66.6% 0% 28% 0% % Exclusions from CGT Annual exclusion for individuals and special trusts: R Exclusion granted to individuals during the year of death: R Exclusion on disposal of a primary residence: R2 million. Exclusion on disposal of a small business for persons over 55: R1.8 million provided that the market value of the business does not exceed R10 million. Value-Added Tax Standard rate on or after 7 April 1993: 14% VAT registration threshold remains at R VAT voluntary registration threshold remains at R

22 Transfer Duties Payable on transactions that are not subject to VAT Value of property R0 R % Rates payable R R % of the value above R R R R R R and above R % of the value above R R % of the value exceeding R R % of the value exceeding R Estate Duty, Donations Tax And Securities Transfer Tax Estate Duty A flat rate of 20% remains on all property of residents and South African property of non-residents. A basic deduction of R 3.5 million is allowed in the determination of an estate s liability for Estate Duty as well as deductions for liabilities, bequests to Public Benefit Organisations ( PBO ) and property accruing to surviving spouses. Donations Tax A flat rate of 20% remains. The first R of property donated in each year, by a natural person, is exempt from donations tax. For taxpayers who are not natural persons, exempt donations are limited to casual gifts not exceeding a total of R per annum. Donations between spouses and donations to PBOs are exempt from donations tax. 20

23 Securities Transfer Tax ( STT ) The tax is imposed at a rate of 0.25% on the transfer of listed or unlisted securities. Tax calendar Provisional tax individuals / companies 1st Payment: To be made within 6 months after previous tax year end 2nd Payment: To be made on tax year end 3rd Payment: Voluntary payment to be made within 7 months after tax year end (if tax year end is 28/29 February), or voluntary payment to be made within 6 months after year end (if tax year end falls on any other date). Individuals who on the last day of the year of assessment will be below the age of 65 years who do not carry on a business and whose taxable income will not exceed the amount of the applicable annual tax threshold, or whose taxable income from interest, foreign dividends and rental will be R or less will be exempt from provisional tax. Individuals who on the last day of the year of assessment will be over the age of 65 years are exempt from provisional tax if they are not directors or private companies and only receive employment income, interest, rental or dividends not exceeding the amount of the applicable annual tax threshold. Provisional tax penalties on late payment, late submission and underestimation The following penalties may be imposed A 10% penalty for the late payment of the amount of provisional tax due A 20% penalty for the late submission of the provisional tax return, or for the underestimation of the amount of provisional tax due 21

24 The 20% underestimation penalty is reduced by the amount of any late payment penalty imposed. Both of these penalties constitute percentage based penalties in terms of section 213 of the Tax Administration Act ( TAA ). The 20% underestimation penalty will only be triggered in the following scenarios Taxable income of less than R 1 million: if the aggregate of the first and second provisional tax payments is less than 90% of the normal income tax payable on assessment, and less than the basic amount i.e. the normal income tax payable per the most recent previous assessment issued Taxable income equal to or more than R 1 million: if the aggregate of the first and second provisional tax payments is less than 80% of the normal income tax payable on assessment, regardless of the basic amount. SARS Interest Rates Effective 1 August 2014 Fringe benefits interest free or low interest loans Effective 1 November 2014 Late or underpayments of tax Refund of overpayments of provisional tax Refund of tax on successful appeal Refund of VAT after prescribed period Late payments of VAT Underpayments of Customs and Excise Duties 6.75% p.a. 9.25% p.a. 5.25% p.a. 9.25% p.a. 9.25% p.a. 9.25% p.a. 9.25% p.a. 22

25 Administrative Non-Compliance Penalties Taxable income for preceding year Assessed Loss R0 R R R Monthly Penalty R250 R250 R500 R R R1 000 R R R2 000 R R R4 000 R R R8 000 Above R R Maximum successive penalties: 36 (SARS in possession of address) or 48 (SARS not in possession of address) Administrative non-compliance is the failure to comply with an obligation imposed by or under a tax Act and is listed in a public notice by the Commissioner. As at 25 February 2015, only the failure by a natural person to submit an income tax return (subject to further other conditions) was listed as a specified non-compliance. 23

26 Understatement Percentage-Based Penalties Behaviour Substantial understatement Reasonable care not taken in completing return No reasonable grounds for tax position Gross negligence Intentional tax evasion 24 Standard case Obstructive or repeat case Voluntary disclosure after notification of audit 10% 20% 5% 0% 25% 50% 15% 0% 50% 75% 25% 0% 100% 125% 50% 5% 150% 200% 75% 10% Voluntary disclosure before notification of audit Understatement means any prejudice to SARS or the fiscus as a result of: a. A default in rendering a return b. An omission from a return c. An incorrect statement in a return d. If no return is required, failure to pay correct amount of tax The burden of proving the facts on which SARS based the imposition of the understatement penalty, is upon SARS.

27 Tax Dispute Resolution and Controversy Services We know the processes We know the people We get the results Dealing with tax disputes can mean uncertainty and complexity. KPMG has the experience to help you take control of the dispute resolution process. We work with our clients to help lessen the likelihood of a challenge or audit before a dispute arises and to resolve those matters that ultimately become the subject of a dispute. Johan van der Walt Head of Dispute Resolution and Controversy Services T: +27 (0) E: johanvdwalt.tax@kpmg.co.za Muhammad Saloojee Head of Corporate Tax T: +27 (0) E: muhammad.saloojee@kpmg.co.za Roula Hadjipaschalis Director, Corporate Tax T: +27 (0) E: roula.hadjipaschalis@kpmg.co.za

28 Contact Us: Johannesburg and Pretoria: Muhammad Saloojee Head of Corporate Tax T: E: Andre Meyburgh Head of Indirect Tax T: E: Venter Labuschagne Head of Customs and Excise T: E: Johan Heydenrych Head of Tax Management Services T: E: Natasha Vaidanis Head of International Tax and Transfer Pricing T: E: Carolyn Chambers Head of Global Mobility Services & Employment Tax Advisory T: E: Cape Town: Deborah Tickle Partner, Corporate and International Tax T: E: Durban: Yasmeen Suliman Partner, Corporate and International Tax T: E: Port Elizabeth: Tanette Nell Associate Director, Corporate Tax T: E: KPMG Services Proprietary Limited, a South African company and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative ( KPMG International ), a Swiss entity. All rights reserved. Printed in South Africa MC The KPMG name, logo and cutting through complexity are registered trademarks or trademarks of KPMG International. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavour to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation.