The South African National Treasury recently issued the first batch of measures to be included in the Taxation Laws Amendment Bill, 2015. One of the key measures is a replacement of the measure introduced in 2013 to counter tax-free corporate migrations.
The measure introduced in 2013 included the provision that when a South African resident company issues shares as consideration for the acquisition of shares in a foreign company, a taxable capital gain will result for the South African resi…