South Africa Updates Interpretation Note on Place of Effective Management in Determining Tax Residence of a Company

The South African Revenue Service (SARS) has published Interpretation Note 6 (Issue 3), which provides guidance on the interpretation and application of the term "place of effective management" in determining the tax residence of a company as one of the considerations under the tie-breaker rule in a tax treaty. The interpretation note replaced the prior version issued in 2015 and takes into account relevant developments since that time, including the 2017 version of the OECD Model Tax Conven…