Hogan Lovells Publications | Tax Alert | 14 July 2016

International developments

On the international front, the OECD has released the BEPS discussion drafts on attribution of profits to permanent establishments and revised guidance on profit splits. 

The discussion draft addresses, among others, the latest thinking regarding the creation of permanent establishments in the context of dependent agents. For international investors in South Africa, this will be important and it can be expected that guidance will be sought from the OECD commentary.

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