Tax on corporate transactions in South Africa: overview

A Q&A guide to tax on corporate transactions in South Africa.

The Q&A gives a high level overview of tax in South Africa and looks at key practical issues including, for example: the main taxes, reliefs and structures used in share and asset sales, dividends, mergers, joint ventures, reorganisations, share buybacks, private equity deals and restructuring and insolvency.

To compare answers across multiple jurisdictions, visit the Tax on corporate transactions Country Q&A tool.

The Q&A is part of the global guide to tax on corporate transactions. For a full list of jurisdictional Q&As visit www.practicallaw.com/taxontransactions-mjg.

Contents

Tax authorities

1. What are the main authorities responsible for enforcing taxes on corporate transactions in your jurisdiction?

The main authority responsible for enforcing taxes on corporate transactions in South Africa is the South African Revenue Service (SARS).

Pre-completion clearances and guidance

2. Is it possible to apply for tax clearances or obtain guidance from the tax authorities before completing a corporate transaction?

The South African Revenue Service (SARS) may issue binding class rulings and binding private rulings upon application. An application for a binding private ruling can be made by a party to a proposed transaction, whereas an application for a binding class ruling is made by a legal person (person) on behalf of a class.

The purpose of the rulings system is to promote clarity, consistency and certainty regarding the implementation of, and application of, a tax Act.

If a ruling applies to a person, then SARS must apply the applicable tax in accordance with the ruling. A ruling will apply if:

  • The provision of the Act at issue is the subject of the advance ruling.

  • The set of facts or the transactions are the same as the particular set of facts specified in the ruling.

  • The set of facts or transactions fall within the effective period of the ruling.

  • The assumptions or conditions imposed by SARS in connection with the ruling have been satisfied.

  • In the case of a binding private ruling the person is an applicant identified in the ruling.

  • In the case of a binding class ruling the person is a "class member" identified in the ruling.

 

Main taxes on corporate transactions

Transfer taxes and notaries' fees

3. What are the main transfer taxes and/or notaries' fees potentially payable on corporate transactions?

Securities transfer tax

Key characteristics. Securities transfer tax is payable on the consideration, closing price or market value (whichever is greater) of the transfer, cancellation or redemption of any listed or unlisted security issued by a company incorporated in South Africa, or outside South Africa, which is listed on the JSE.

Triggering event. The tax is triggered on transfer of the security.

Liable party/parties. In the case of a transfer of a listed security to or from a member or a participant, such member or participant is liable for the securities transfer tax on the consideration so received. The member or participant can recover the securities transfer tax paid from the person to whom the security is transferred.

In the case of an unlisted security, the company that issued the security is liable for the securities transfer tax and this can be recovered from the person to whom the security is transferred.

Applicable rate(s). Securities transfer tax is levied at a rate of 0.25%.

Transfer duty

Key characteristics. Transfer duty is levied on the value of any immovable property acquired by a person.

Property broadly means land and any fixtures on the land, including:

  • Any real right in land.

  • Any right to minerals.

  • Any lease or sublease of such right.

  • A share in a residential property company.

Triggering event. The duty is payable on acquisition of the property. Property includes land and any fixtures thereon (see above, Transfer duty: Key characteristics).

Liable party/parties. The person who acquired the property.

Applicable rate(s). Transfer duty is payable according to a sliding scale ranging from 0% where the value of the property does not exceed ZAR600,000 and 8% where the value of the property exceeds ZAR1.5million.

Corporate and capital gains taxes

4. What are the main corporate and/or capital gains taxes potentially payable on corporate transactions?

Corporate income tax

Key characteristics. Corporate income tax is payable on the taxable income received by a company during its financial year. The taxable income is the amount remaining, after deducting any allowable expenditure from the income of a company.

Triggering event. Corporate income tax is triggered when a company calculates taxable income at the end of its financial year. The company must submit a tax return reflecting its income and allowable expenditure. The South African Revenue Service (SARS) assesses the amount of tax payable and the company is issued an assessment reflecting the amount of tax due.

Liable party/parties. The company reflecting the taxable income is liable for tax on that income.

Applicable rate(s). The corporate tax rate is currently 28%.

Capital gains tax

Key characteristics. Capital gains tax is a tax that is levied on the taxable capital gain of a person. The taxable capital gain of a company is 66.6% of the amount by which that company's aggregate capital gain exceeds its assessed capital loss for the previous year of assessment.

A capital gain is calculated as the difference between the base cost of the asset and the proceeds derived from the disposal.

Where the status of a person or an asset changes there will be a deemed disposal for capital gains tax purposes. The base cost of the asset after the change is the market value on the date of the change. A deemed disposal will typically occur where:

  • A capital asset is converted to trading stock.

  • There is a variation of the rights attaching to a share.

Triggering event. Capital gains tax is triggered when a company disposes of an asset for proceeds.

Liable party/parties. The company disposing of the asset is liable for capital gains tax.

Applicable rate(s). The taxable capital gain of the company is included in its taxable income and accordingly is taxed at the corporate tax rate of 28%. The effective capital gains tax rate for companies is therefore 18.65%.

Value added and sales taxes

5. What are the main value added and/or sales taxes potentially payable on corporate transactions?

VAT

Key characteristics. VAT must be charged and paid over by all suppliers of goods and services. All suppliers of goods and services with an annual turnover exceeding ZAR1 million must register as VAT vendors and charge output VAT. Other vendors may elect to register for VAT provided their annual turnover exceeds ZAR50,000.

If they do not register they are prohibited from charging VAT on goods or services they supply and from claiming an input tax on goods and services which they acquire.

Triggering event. The following act as triggers:

  • The supply of goods and services by a vendor in the course of carrying on an "enterprise". An "enterprise" broadly means any activity carried on in the Republic in the course of which goods and services are supplied for consideration.

  • The import of goods into South Africa.

  • The supply of imported services by any person.

Liable party/parties. The following are liable parties:

  • A registered vendor.

  • An importer of goods.

  • A supplier of imported services.

Applicable rate(s). A standard rate of 14% applies, however certain goods and services are levied at a 0% VAT rate.

Turnover tax

Key characteristics. Businesses with a turnover not exceeding ZAR1 million may elect to be declared micro businesses and pay a turnover tax instead of income tax. Micro businesses cannot register as VAT vendors.

Turnover tax is calculated by applying a tax rate to the taxable turnover of a micro business. For the period 1 April 2014 to 31 March 2015 the following rates apply:

  • ZAR0 to ZAR150,000 = 0%.

  • ZAR150,001 to ZAR300,000 = 1% of each ZAR1 above ZAR150,000.

  • ZAR300,001 to ZAR500,000 = ZAR1,500 plus 2% of the amount above ZAR300,000.

  • ZAR500,001 to ZAR750,000 = ZAR5,500 plus 4% of the amount above ZAR500,000.

  • ZAR750,000 and above = ZAR15,500 plus 6% of the amount above ZAR750,000.

Other taxes on corporate transactions

6. Are any other taxes potentially payable on corporate transactions?

Donations tax

Key characteristics. A tax of 20% is imposed on donations made by residents. A donation is a gratuitous disposal of property including a gratuitous waiver or renunciation of a right. Persons other than natural persons can make casual donations of not more than ZAR10,000 per annum without incurring the tax.

The following are exempt from donations tax:

  • Public companies.

  • Donations in the public interest to recognised public benefit organisations.

  • Donations to institutions for the advancement of science or art.

  • Donations to political parties and spheres of government.

  • Donations between members of the same group of companies.

Triggering event. A disposal by a resident.

Liable party/parties. The donor.

Applicable rates. 20% of the value of the property.

Taxes applicable to foreign companies

7. In what circumstances will the taxes identified in Questions 3  ( www.practicallaw.com/4-385-8916) to 6 be applicable to foreign companies (in other words, what "presence" is required to give rise to tax liability)?

Securities transfer tax

See Question 3, Securities transfer tax.

Corporate income tax

Key characteristics. See Question 4, Corporate income tax: Key characteristics.

Triggering event. See Question 4, Corporate income tax: Triggering event.

A foreign company is considered resident, and thereby subject to tax in South Africa, if it has its place of effective management in South Africa (subject to the provisions of the relevant double taxation agreement between South Africa and the country in question).

If the foreign company is not resident for South African tax purposes, it may still be subject to tax on income that is sourced from South Africa.

Liable party/parties. See Question 4, Corporate income tax: Liable party/parties.

Applicable rate(s). See Question 4, Corporate income tax: Applicable rate(s).

Capital gains tax

Key characteristics. See Question 4, Capital gains tax: Key characteristics.

A non-resident company will be subject to capital gains tax on the disposal of:

  • Immovable property situated in the Republic and any interest or right of that person in immovable property situated in South Africa. (An interest in immovable property situated in South Africa includes equity shares held by that person in a company in which 80% of the market value of those equity shares are attributable directly or indirectly to immovable property and that person holds at least 20% of the equity shares in that company.)

  • Any asset that is attributable to a permanent establishment of that person in the Republic.

Triggering event. See Question 4, Capital gains tax: Triggering event.

Liable party/parties. See Question 4, Capital gains tax: Liable party/parties.

Applicable rate(s). See Question 4, Capital gains tax: Applicable rate(s).

VAT

Key characteristics. A non-resident will be subject to VAT if it supplies goods and services in the Republic or partly in the Republic for consideration.

Triggering event. The supply of goods and/or services in or partly in the Republic for consideration.

Liable party/parties. If the foreign company carries on an enterprise and the value of the taxable supplies in the preceding 12 months exceed ZAR1million, then such person must register for VAT.

Applicable rate(s). Currently 14% on the value of goods and services supplied.

 

Dividends

8. Is there a requirement to withhold tax on dividends or other distributions?

Dividends that are paid by a company that is resident are subject to dividends tax. Dividends tax is levied at a rate of 15% on the amount of the dividend paid.

In certain instances a company is exempt from withholding dividends tax. Typical examples include where dividends are declared and paid to a resident company. The relevant double taxation agreement in place between South Africa and the other contracting state may reduce the withholding tax on the dividends.

 

Share acquisitions and disposals

Taxes potentially payable

9. What taxes are potentially payable on a share acquisition/share disposal?

Securities transfer tax

On acquisition and disposal of shares, securities transfer tax is payable. See Question 3, Securities transfer tax.

Capital gains tax

Capital gains tax is levied on the disposal of shares held for investment purposes, see Question 4, Capital gains tax. Shares that are held for a period of three years are deemed to be capital.

The amount of expenditure actually incurred on the acquisition of the asset will form part of the base cost of that asset.

Corporate income tax

Any profit realised on the disposal of shares that are held for trading purposes is included in the taxable income of a company. See Question 4, Corporate income tax.

A company trading in shares includes the proceeds of the shares it disposes of in its gross income and claims the cost of the shares it acquires as a deduction. In addition, it takes into account its holdings of shares at the beginning and end of its year of assessment as opening and closing stock for the purpose of calculating its taxable income.

VAT

There is no VAT payable on the transfer of shares as this constitutes an exempt supply for tax purposes.

Exemptions and reliefs

10. Are any exemptions or reliefs available to the liable party?

Reliefs are available to the liable party to the extent that the group-relief provisions are applicable to the sale of shares transaction. See Question 27.

Tax advantages/disadvantages for the buyer

11. Please set out the tax advantages and disadvantages of a share acquisition for the buyer.

Advantages

Dividends received on shares are exempt from income tax.

Disadvantages

To the extent that the shares are acquired as capital assets, any interest expenditure incurred on debt acquired to fund the purchase is not deductible for tax purposes, unless the interest is incurred on shares acquired in an operating company.

Tax advantages/disadvantages for the seller

12. Please set out the tax advantages and disadvantages of a share disposal for the seller.

Advantages

Shares held as capital assets are subject to tax at the capital gains tax rate (effectively 18.65% for companies).

Disadvantages

Dividends declared are not eligible for a deduction. Proceeds on the disposal of shares that are held on a trading account are taxed at the corporate tax rate of 28%.

Transaction structures to minimise the tax burden

13. What transaction structures (if any) are commonly used to minimise the tax burden?

The interest expenditure incurred on any debt is only allowed as a deduction where it is incurred in the production of income. As dividends are exempt for tax purposes, there are limited structures available to avoid the non-deductibility of interest on the acquisition of shares. Where however a debt is assumed for the purpose of financing the acquisition of equity shares in an "operating company" as defined, such interest expenditure is deemed to have been incurred in the production of income and therefore may be allowed as a deduction for income tax purposes.

 

Asset acquisitions and disposals

Taxes potentially payable

14. What taxes are potentially payable on an asset acquisition/asset disposal?

Capital gains tax

Assets held as capital assets are subject to capital gains tax on the disposal of those assets, see Question 4, Capital gains tax.

VAT

Where assets are acquired from another vendor, VAT is levied at the current rate of 14%. In the event that no VAT is payable on acquisition of the assets, transfer duty will be applicable.

Where assets are transferred as part of a sale of a business as a going concern, the VAT on the sale is zero rated if certain requirements are met.

Exemptions and reliefs

15. Are any exemptions or reliefs available to the liable party?

VAT

Where the group-relief provisions are applied to a transaction, there is no VAT on the sale of the assets (see Question 26).

Capital gains tax

A taxpayer can roll-over capital gains where there is an involuntary disposal, if certain requirements are met.

Group roll-over relief

The company disposing of the asset may apply group-relief if applicable given the relevant facts and circumstances (see Question 27).

Tax advantages/disadvantages for the buyer

16. Please set out the tax advantages and disadvantages of an asset acquisition for the buyer.

Advantages

The interest incurred on debt to fund the acquisition of the asset is allowed as a tax deduction.

The buyer may also be eligible to claim capital allowances on the assets.

Disadvantages

To the extent that the group-relief provisions are applied to the transaction, the buyer acquires the asset for a deemed cost equal to the expenditure incurred by the seller in respect of the asset (that is, the base cost for the seller). The base cost of the asset is therefore lower than it would have been if the buyer had acquired the asset at a market related price, which will result in an increased capital gain being realised upon the eventual disposal of the asset by the buyer.

Tax advantages/disadvantages for the seller

17. Please set out the tax advantages and disadvantages of an asset disposal for the seller.

Advantages

Where the seller applies the group-relief provisions to the sale of the assets, the capital gains tax and/or corporate income tax implications are deferred.

Disadvantages

Where the group-relief provisions are not applied to the transaction, the seller is liable for capital gains tax and/or corporate income tax on the gain realised on the disposal, as the case may be.

Transaction structures to minimise the tax burden

18. What transaction structures (if any) are commonly used to minimise the tax burden?
 

Legal mergers

Taxes potentially payable

19. What taxes are potentially payable on a legal merger?

Capital gains tax and corporate income tax rules apply to the transactions unless the group-relief provisions apply.

Corporate income tax

The disposal of allowance assets may lead to income tax recoupments.

Capital gains tax

Capital gains tax is applicable on the disposal of assets, unless the group-relief provisions are applied to the transaction (if the relevant requirements are met). Furthermore, the liquidation of a company may also have capital gains tax consequences for the company and the shareholders.

Securities transfer tax

Securities transfer tax may be payable if shares are transferred as part of the transaction, see Question 3, Securities transfer tax.

No securities transfer tax is payable if the group-relief provisions are applied to the transaction.

VAT

VAT is levied on the disposal of any assets (excluding shares) unless the group-relief provisions (excluding unbundling transactions) are applied to the transaction, in which event the seller and the buyer are deemed to be one and the same persons for VAT purposes (that is, no VAT is payable in certain circumstances).

Group-relief provisions

See Question 27.

Exemptions and reliefs

20. Are any exemptions or reliefs available to the liable party?

Transaction structures to minimise the tax burden

21. What transaction structures (if any) are commonly used to minimise the tax burden?
 

Joint ventures

Taxes potentially payable

22. What taxes are potentially payable on establishing a joint venture company (JVC)?

Corporate income tax

The tax implications of establishing a joint venture will depend on the structuring of the transaction.

Where the joint venture is conducted through a company which is incorporated in South Africa, it is subject to income tax at the corporate tax rate which is currently 28%.

If however the joint venture is conducted through a partnership, it is not regarded as a "person" for corporate income tax and as such the partners are taxed on their share of the partnership profit.

VAT

A joint venture which is a company or a partnership must levy VAT at the standard rate of 14% on the value of all taxable supplies in the course or furtherance of an enterprise as defined.

Securities transfer tax

A transfer of securities does not include the issue of shares and as such shares that are issued by the joint venture are not subject to securities transfer tax.

Exemptions and reliefs

 
23. Are any exemptions or reliefs available to the liable party?

Depending on how the joint venture is established, the group-relief provisions may apply (see Question 27).

Transaction structures to minimise the tax burden

24. What transaction structures (if any) are commonly used to minimise the tax burden?

Depending on how the joint venture is established, the group-relief provisions may apply (see Question 27).

 

Company reorganisations

Taxes potentially payable

25. What taxes are potentially payable on a company reorganisation?

The below taxes may typically arise in respect of a company reorganisation.

Capital gains tax

Capital gains tax is applicable on the disposal of assets, unless the group-relief provisions are applied to the transaction (if the relevant requirements are met) (see Question 27).

Securities transfer tax

Securities transfer tax may be payable if shares are disposed of as part of the transaction. The securities transfer tax is payable by the company that issued the shares, however the amount of securities transfer tax paid can be recovered from the person to whom the shares are transferred (see Question 3, Securities transfer tax). No securities transfer tax is payable if the group-relief provisions are applied to the transaction.

VAT

VAT is levied on the disposal of any assets (excluding shares) unless the group-relief provisions (excluding unbundling transactions) are applied to the transaction, in which event the seller and the buyer are deemed to be one and the same persons for VAT purposes (that is, no VAT is payable in certain circumstances).

Exemptions and reliefs

26. Are any exemptions or reliefs available to the liable party?

VAT

If the requirements of the group-relief provisions are met (see Question 27), the purchaser and the seller to the agreement are deemed to be one and the same person for VAT purposes. An unbundling transaction does not qualify for this relief.

Securities transfer tax

Where the group-relief provisions are applied to a transaction (see Question 27) no securities transfer tax is payable.

Capital gains tax and corporate income tax

Where the group-relief provisions are applied to a transaction (see Question 27) the capital gains tax and corporate income tax may be deferred.

Transfer duty

Where the group-relief provisions are applied to a transaction (see Question 27) no transfer duty is payable. An unbundling transaction does not qualify for this relief.

Transaction structures to minimise the tax burden

27. What transaction structures (if any) are commonly used to minimise the tax burden?

The tax regime in South Africa allows relief in respect of transactions between group companies. A broad summary of each of the group-relief provisions are provided below:

  • Asset-for-share transactions. An asset-for-share transaction is one in which a person disposes of an asset to a company which is resident in exchange for the issue of an equity share in that company. The asset is deemed to have been disposed of for proceeds equal to the base cost of the asset, thereby effectively deferring the CGT event on the disposal.

  • Amalgamation transactions. An amalgamation transaction is one in terms of which a company which is a resident disposes of all of its assets to another company which is a resident by way of an amalgamation, conversion or merger and as a result of which the existence of the amalgamated company is terminated. The asset is deemed to have been disposed of for proceeds equal to the base cost of the asset, thereby effectively deferring the capital gains tax event on the disposal.

  • Intra- group transactions. In terms of an intra-group transaction, an asset is disposed of by one company to another company that is a resident and both companies form part of the same group of companies for tax purposes. The asset is deemed to have been disposed of for proceeds equal to the base cost of the asset, thereby effectively deferring the capital gains tax event on the disposal. Section 23N of the Income Tax Act 1962 may apply to limit the deductibility of interest by the acquiring company in respect of debt incurred to facilitate the reorganisation transaction.

  • Unbundling transactions. An unbundling transaction is one where the equity shares in a company which is a resident (the unbundled company) that are held by a company that is a resident (the unbundling company) are all distributed by that unbundling company to any shareholder of that unbundling company in accordance with the effective interest of the shareholders in the shares of that unbundling company.

  • Liquidation transactions. A liquidation transaction is one in which a company which is a resident disposes of all of its assets to its shareholders in anticipation of its liquidation, only to the extent that such shareholders form part of the same group of companies for tax purposes. Section 23N of the Act may apply to limit the deductibility of interest by the acquiring company in respect of debt incurred to facilitate the reorganisation transaction.

 

Restructuring and insolvency

28. What are the key tax implications of the business insolvency and restructuring procedures in your jurisdiction?

Capital gains tax and assessed loss

The liquidating company is subject to capital gains tax on the distribution in specie of the assets to its shareholders for proceeds equal to the market value of the assets, unless the group-relief provisions are applied to the transaction (see Question 27) in which event the liquidating company is deemed to have disposed of the assets for proceeds equal to the base cost of those assets (therefore, no capital gains tax is payable).

The liquidating company cannot carry forward any assessed loss incurred prior to the liquidation date.

Distribution in specie and return of capital

Distribution in specie received before liquidation. The owner is deemed to have acquired the assets for an amount equal to the market value of the assets on that date.

Where the group-relief provisions are applied to the transaction, the owner of the shares is deemed to have acquired the assets for an amount equal to the base cost of those assets.

Return of capital received before liquidation. Where a return of capital is received after 1 April 2012, but before the deregistration of the company, the owner of the share must reduce the expenditure in respect of that share by the amount of cash or the market value of the assets received. Where the group-relief provisions are applied to the transaction, the owner of the shares must disregard the return of capital received for purposes of determining its aggregate capital gain or aggregate capital loss.

Return of capital received after liquidation. Where a return of capital is received after the date of liquidation, the owner of the shares is treated as having disposed of all the shares in the liquidating company for a capital gain equal to the return of capital received. Where the group-relief provisions are applied to the transaction, the owner of the shares must disregard the return of capital received for purposes of determining its aggregate capital gain or aggregate capital loss.

Creditors

The South African Revenue Service (SARS) becomes a preferential creditor in the event of liquidation. Other creditors may be eligible to claim a deduction of debt that has gone bad during the year of assessment, provided that such amount was included in its income for either the current or the previous year of assessment.

 

Share buybacks

Taxes potentially payable

29. What taxes are potentially payable on a share buyback? (List them and cross-refer to Questions3to 6 as appropriate.)

Dividends tax

An amount that is transferred or applied by a company in respect of a share buyback will constitute a dividend which is subject to dividends tax, provided that such amount does not constitute contributed tax capital of the company making the payment.

Securities transfer tax

The company may be subject to securities transfer tax on the transfer of the shares (see Question 3).

Exemptions and reliefs

30. Are any exemptions or reliefs available to the liable party?

Dividends that are declared to a resident company are not subject to dividends tax and the dividend received by the shareholder is exempt from income tax.

Transaction structures to minimise the tax burden

31. What transaction structures (if any) are commonly used to minimise the tax burden?

There are no specific provisions available to minimise the tax implications on a share buyback transaction.

 

Private equity financed transactions: MBOs

Taxes potentially payable

32. What taxes are potentially payable on a management buyout (MBO)?

Corporate income tax

The interest incurred on debt utilised to fund the acquisition of shares is not allowed as a deduction for tax purposes. This is because the interest expense is not incurred in the production of income (that is, the dividends earned on the shares are exempt from income tax).

Capital gains tax

Where there is a disposal of assets in respect of a MBO, there may be capital gains tax consequences (see Question 4).

Exemptions and reliefs

33. Are any exemptions or reliefs available to the liable party?

Where a company assumes debt for the purpose of acquiring equity shares in an "operating company" as defined, such interest expenditure is deemed to have been incurred in the production of income and laid out for the purposes of trade. The company and the operating company must form part of the same "group of companies" as defined.

Transaction structures to minimise the tax burden

34. What transaction structures (if any) are commonly used to minimise the tax burden?

Where applicable, group-relief provisions may be applied to the transaction (see Question 27).

 

Reform

35. Please summarise any proposals for reform that will impact on the taxation of corporate transactions.

Currently the outcome of the OECD BEPS analysis is being reviewed by the Davis Tax Committee. In addition the committee will also review VAT, mining companies and insurance companies.

 

Online resources

The South African Revenue Service (SARS)

W www.sars.gov.za

Description. Official website of the SARS. Content is available in English.



Contributor profiles

Andrew Wellsted

Norton Rose Fulbright

T +27 11 685 8809
F +27 11 301 3200
E Andrew.Wellsted@nortonrosefulbright.com
W www.nortonrosefulbright.com/za

Professional qualifications. South Africa, Attorney (BA, 1996; LLB, 1998; LLM (Tax) 2002)

Areas of practice. South African tax and exchange control.

Elana Ross

Norton Rose Fulbright

T +27 11 685 8846
F +27 11 301 3200
E Elana.ross@nortonrosefulbright.com
W www.nortonrosefulbright.com/za

Professional qualifications. CA (SA) 2013 (Bcom 2008, Bcom (Hons) 2009)

Areas of practice. South African tax and international tax


{ "siteName" : "PLC", "objType" : "PLC_Doc_C", "objID" : "1247243324247", "objName" : "Tax on Corporate Transactions South Africa", "userID" : "2", "objUrl" : "http://us.practicallaw.com/cs/Satellite/us/resource/4-385-8916?q=*&qp=&qo=&qe=", "pageType" : "Resource", "academicUserID" : "", "contentAccessed" : "true", "analyticsPermCookie" : "2-1b93f46a:14e3ed06c21:7f44", "analyticsSessionCookie" : "2-1b93f46a:14e3ed06c21:7f45", "statisticSensorPath" : "http://analytics.practicallaw.com/sensor/statistic" }