Dividends tax: One year into the system
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1 Dividends tax: One year into the system Prof Pieter van der Zwan 1 Introduction Developments in taxation of dividends Amendments to the definition of 'dividend' and introduction of CTC concept 1/5/2011 STC replaced by dividends tax and amendments to 'dividend' 1/1/2011 Companies Act 2008 became effective 1/4/2012 1
2 Overview of the session Taxation of dividends Basics of dividends tax Practical issues with dividends tax Section 46 of the Companies Act Distributions A company must not make any proposed distribution unless The distribution is pursuant to existing obligation/court order or board of the company has authorised it by resolution it reasonably appears that the company will satisfy the solvency and liquidity test immediately after completing the proposed distribution the board of the company, by resolution, has acknowledged that it has applied the solvency and liquidity test, as set out in section 4, and reasonably concluded that the company will satisfy the solvency and liquidity test immediately after completing the proposed distribution. distribution means a direct or indirect (a) transfer by a company of money or other property of the company, other than its own shares, to or for the benefit of one or more holders of any of the shares (b) incurrence of a debt or other obligation by a company for the benefit of one or more holders of any of the shares of that company. 2
3 What is a dividend for tax? From 1/4/2012 Foreign dividend defined separately means any amount transferred or applied by a company that is a resident Who else? for the benefit or on behalf of any person in respect of any share in that company whether that amount is transferred or applied (a) by way of a distribution Returns of capital (b) as consideration for the acquisition of any share in that company but does not include any amount so transferred or applied by the company to the extent that the amount so transferred or applied (i) results in a reduction of contributed tax capital; Exemption of dividend income Gross income par (k): All dividends received included in gross Dividends income Section 10(1)(k)(i) SA dividends exempt Except for a number of exceptions that are not exempt 3
4 Overview of the session Taxation of dividends Basics of dividends tax Practical issues with dividends tax Effective date of the Dividends Tax (DT) regime Dividends tax applies to dividends declared and paid on or after 1 April 2012 Dividends subject to STC are specifically excluded from DT (s 64F(m)) 4
5 Effective date of the Dividends Tax (DT) regime Dividend cycle ends on day that dividend 'declared' accrues to a shareholder declared, in relation to any dividend (including a dividend in specie), means the approval of the payment or distribution thereof by the directors of the company or by some other person with comparable authority or, in the case of the liquidation of a company, by the liquidator thereof Amendment to the provisions dealing with accrual date: Dividend declared before 1 April 2012 that will only accrue after 1 April 2012 must be deemed to have accrued to a shareholder on 31 March Back-dated dividends? Calculation of DT (s 64E(1)) Dividends tax levied on any dividend paid by a company other than a headquarter company: Dividend paid 15% NB: No deduction for dividends received 5
6 Dividends subject to DT (s 64D) Dividends tax levied on any dividend paid by a company other than a headquarter company: dividend means any dividend or foreign dividend as defined in section 1 that is (a) paid by a company that is a resident; or (b) paid by a company that is not a resident (i) if the share in respect of which that foreign dividend is paid is a listed share; and (ii) to the extent that that foreign dividend does not consist of a distribution of an asset in specie Other amendments coinciding with introduction of dividends tax Personal Service Provider tax rates reduced to 28% Foreign company tax rates reduced to 28% 6
7 Timing of DT (s 64E(2)) Dividends tax levied on any dividend paid by a company other than a headquarter company: A dividend is deemed to be paid on the earlier of the date on which the dividend is paid or becomes payable by the company that declared the dividend. Dividend declared on loan account? Amount of dividend (s 64E(3)) Dividends tax levied on any dividend paid by a company other than a headquarter company: Dividend paid 15% Examples of dividends in specie? If dividend is distribution of asset in specie, the amount of the dividend in the market value of the asset on the date that the dividend is paid 7
8 Liability for DT (s 64EA) Person liable for DT If dividend is not distribution of an asset in specie Beneficial owner Withheld by the company declaring the dividend or regulated intermediary If dividend is distribution of an asset in specie Company Similar to STC Liability to withhold DT from dividends, other than dividends in specie (s 64G) General rule: Company must withhold 15% on dividend not paid in specie, unless one of the exceptions apply Exception: Company need not withhold DT Exception: Company must withhold at lower rate 8
9 1 When does a company not have to withhold DT? (s 64G(2)) By the date determined by company (or otherwise date when dividend paid): Written declaration from beneficial owner that dividend should be exempt i.t.o. S 64F AND Undertaking to notify company if beneficial ownership changes Company declaring dividend need not withhold 15% if: What happens if the company does not have this documentation? Refunds Summary of procedure Dividend declared, no declaration by recipient Recipient now submits declaration 3 year period 1 year Refund made from DT withheld in this period If not yet refunded by this date, company should request refund from SARS (this may not be more than 4 years after date that dividend was paid) 9
10 Beneficial owner (s 64D) beneficial owner means the person entitled to the benefit of the dividend attaching to a share Shares held by a trust? Dividends exempt from DT (s 64F) The following dividends (not in specie) are exempt from DT if beneficial owner isa company which is a resident the Government, a provincial administration or a municipality a public benefit organisation approved by the Commissioner a trust contemplated in section 37A an institution, board or body contemplated in section 10 (1) (ca) a fund contemplated in section 10 (1) (d) (i) or (ii) a person contemplated in section 10 (1) (t) Shareholder registered as micro business (R p.a.) Non-resident, in respect of dividend declared by a listed foreign company (par (b) of dividend in section 64D definition) 10
11 When does a company not have to withhold DT? (s 64G(2)) (continued) 1 By the date determined by company (or otherwise date when dividend paid): Written declaration from beneficial owner that dividend should be exempt i.t.o. S 64F AND Undertaking to notify company if beneficial ownership changes Company declaring dividend need not withhold 15% if: 2 Beneficial owner part of same group of companies (s 41) as company paying dividend 3 Dividend paid to a regulated intermediary Liability for DT (s 64EA) Person liable for DT If dividend is not distribution of an asset in specie Beneficial owner Withheld by the company declaring the dividend or regulated intermediary If dividend is distribution of an asset in specie Company Similar to STC 11
12 Exemption from DT for dividend in specie (s 64FA) Dividend in distribution of an asset in specie is exempt from DT if: The person to whom the dividend is paid, submitted to the company Declaration from beneficial owner stating that the dividend would have been exempt if it was not a dividend in specie Written undertaking to inform the company in writing if that person is no longer the beneficial owner OR Beneficial owner is part of the same group of companies (s 41) OR Dividend constitutes a par 51A of Eighth Schedule disposal Example: DT mechanism Non-exempt shareholder Company B 100% Company A Profit for the year (after income tax) = R1 million Requires R for day-to-day business needs Remaining R available for distribution 12
13 Example: DT mechanism In the hands of Company A Dividend declared to Company B Company B holds 100% of the shares of Company A, therefore group companies (if both companies residents then group companies i.t.o. s 41). Therefore Company A does not have to withhold DT (s 64F(2)) What if Company B only held 60% of the shares in Company A? No longer group companies Dividends to resident companies exempt, provided that notification and undertaking Example: DT mechanism In the hands of Company A No journal entries for DT, as no amounts withheld Journal entry to record dividend paid: Dr Dividend paid R Cr Bank R
14 Example: DT mechanism In the hands of Company B Dividend declared to natural person shareholder Unless the natural person is exempt from DT, this dividend will be subject to DT Company B must withhold at a rate of 15% Dividend paid: R Withhold: R x 15% = R Example: DT mechanism In the hands of Company B Journal entry to record dividend received: Dr Bank R Cr Dividend income (I/S) R Journal entry to record dividend paid: Dr Dividend paid R Cr Bank/dividend payable R Cr SARS (DT withheld) R Company B: Income statement Dividend received R Profit for the year R
15 Example: DT mechanism In the hands of Shareholder Dividend declared by Company B Dividend received = R DT paid = (R ) Exempt income Shareholder : Income statement Dividend received R DT expense (R ) Profit for the year R Example: DT mechanism In the hands of Company A If this was a dividend in specie of an asset with MV of R ? Dividend declared to Company B If Company B submitted a notification that dividend would have been exempt if not in specie and undertaking to notify Company A if there is a change in beneficial ownership, then exempt If no such declaration, then Company A would be liable to pay DT Tax expense would have been included in Company A s income statement in this case If Company B declared dividend in specie to shareholder? 15
16 Comparison: STC vs DT (Assuming that all roll-over relief/exemptions used) Company A has R available to distribute STC DT DT (in specie) Company A: Dividend R R R Expense (I/S) - (Roll-over) - - (exempt) Company B: Dividend paid R R R Dividend received R (exempt) R R Expense (I/S) (R68 181) - (R ) Shareholder: Dividend received R R R Expense (I/S) - (R ) - Cash received R R Asset, no cash Choice at liquidation Company A (natural person as shareholder) will be voluntarily liquidated. The company has an asset to the value of R1 million (assume also a base cost of R1 million) and cash of R Should the asset be distributed as a dividend in specie or sold and the cash be distributed as a dividend. If asset turned into cash, then R distributed: DT on cash distributed = R x 15% = R If asset distributed as dividend in specie: DT payable to Co = R x 15% = R Cash remaining: R R = R DT on cash distributed = R x 15% = R
17 Overview of the session Taxation of dividends Basics of dividends tax Practical issues with dividends tax Documents required DTR01 and DTR02 form to be submitted E-filing/Easyfile/Direct data transfer From 1 April 2013, also indicate information on dividends received No requirement for IT3(b) 17
18 Last STC dividend cycle Dividend declared 1/4/2012 Start of new dividend cycle This cycle is likely to result in R nil or negative net dividend amount Last dividend cycle deemed to end on 31/3/2012 What happens to STC credits that exist at 31/3/2012? (s 64J) To the extent a dividend paid by a a company does not exceed the company s STC credits available, dividends declared by that company are not subject to DT provided that the company has notified the person to whom the dividend is paid of the amount of the dividend that reduces the company s STC credit If inaccurate, company liable for other person s DT Calculation of a company s STC credit: (s 64J(2)) STC credit at 31/3/2012 Plus: Dividends received where company indicated that paid from the company s STC credits Less: Dividends declared and paid by the company after effective date 18
19 What happens to STC credits that exist at 31/3/2012? (s 64J) (2) After the third anniversary of the effective date (i.e. 1/4/2015), the STC credit of a company will be deemed to be R Nil Example: STC credits Company Z has two shareholders, namely: (1) Company A (60% shareholder) (2) Natural person B (40% shareholder) Company A s shareholder in Natural person C (100% shareholder). On 31/3/2012 Company Z had unused STC credits of R1 million. On 30 April 2012 Company Z paid a dividend of R to its shareholders. Company Z notifies the shareholders that the amount of R was paid from STC credits. Company A passes on its dividend to Natural Person C. 19
20 Example: STC credits Natural person B Natural person C Company A STC credit (dividend received from Company Z) R R Dividend declared and paid after effective date (R ) Company Z R STC credits before dividend Dividend declared and paid after effective date R (R ) Accounting for STC credits (1) Position prior to 1/4/2012 Deferred tax asset was recognised for STC credits (provided that the company was expected to declare dividends in future against which the STC credit could be utilised), as the STC credit reduced the company s future tax liability. Issue with the introduction of DT: Can the company still recognise a deferred tax asset for STC credits, as these credits will now reduce the shareholder s DT liability, no longer the company s future tax liability. 20
21 Accounting for STC credits (2) SAICA Circular 3/2011 The company can no longer recognise a deferred tax asset, as the benefit of the STC credit is now enjoyed by the shareholder as opposed to the company Derecognition of deferred tax asset through profit or loss (not equity) Deemed dividends on debit loans Specific provision: Section 64E(4) Company Debt Person (other than a company) that is a resident and connected person in relation to the company OR This person s connected person Company deemed to have paid a dividend if loan by virtue of shareholding Amount of deemed dividend: Greater of: Deemed dividend in specie official rate actual interest R Nil 21
22 Deemed dividends on debit loans from 1/4/2012 Intercompany loans? Loans to trusts? Short-term loans? Employee loans? Deemed dividend transitional provision New section 64E(4)(e): A loan that was deemed to be a dividend for purposes of STC will not be subject to section 64E(4) What about writing off such a loan? 22
23 Withholding DT at a reduced rate Withhold DT from the payment of a dividend at a reduced rate if the person to whom the payment is made has: By the determined date, or otherwise date when dividend is paid submitted the following to the company: a declaration by the beneficial owner in such form as may be prescribed by the Commissioner that the dividend is subject to that reduced rate as a result of the application of an agreement for the avoidance of double taxation AND a written undertaking in such form as may be prescribed by the Commissioner to forthwith inform the company in writing should the beneficial owner cease to be the beneficial owner. DTA between SA and NZ on taxation of dividend income (Art 10(2)) However, such dividends may also be taxed in the Contracting State of which the company paying the dividends is a resident for the purposes of its tax, and according to the laws of that State, but the tax so charged shall not exceed: (b) in the case of South Africa: (i) 5 per cent of the gross amount of the dividends if the beneficial owner is a company which holds at least 25 per cent of the capital of the company paying the dividends; or (ii) 15 per cent of the gross amount of the dividends in all other cases. 23
24 DTA between SA and Seychelles on taxation of dividend income (Art 10(1)) Dividends paid by a company which is a resident of a Contracting State to a resident of the other Contracting State shall be taxable only in that other State, provided such resident is the beneficial owner of the dividends. Concept of passive holding companies (was contained in s 9E before its scrapping) Passive HoldCo Purpose to defer DT payment Company X Company Z Company Y 24
25 Closing the loophole with exempt persons (section 64EB) 2 Exempt person (s 64F) Shareholder cedes right to dividend to Exempt person Shareholder Ceded dividend is deemed to be a dividend paid for the benefit of the ceding shareholder 1 Declare or announce dividend SACo Applies to transactions entered into on or after 1 Sept 2012 and amounts paid on or after 1 October 2012 in respect of transaction entered into before 1 September 2012 Next session Topic: Tax implications of corporate restructuring activities with a focus on smaller entities 25
26 Questions Presenter s contact details Pieter van der Zwan pieter.vanderzwan@nwu.ac.za pieter@pvdz.co.za 26
27 Thank you
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