ARTICLE
2 July 2026

Higher Education Sector: Key Tax Considerations

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SNG Grant Thornton

Contributor

SNG Grant Thornton is the South African member firm of Grant Thornton International Ltd. We have progressed expeditiously in every aspect since our establishment in 1985. We are an indigenous mid-tier assurance, tax and advisory firm with offices in South Africa and Eswatini.
Higher education institutions are navigating an increasingly complex tax landscape as they diversify revenue streams, expand internationally, and transform their operational models. From VAT complications on mixed activities to intricate employee taxation and global mobility challenges, universities face mounting compliance pressures that demand strategic attention and proactive management.
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QUICK SUMMARY

Higher education institutions face growing tax complexity as they persify income, expand globally, and evolve their operations. This increases exposure across VAT, employee taxation, and corporate tax.

Key challenges include managing VAT on mixed activities, navigating complex remuneration and global mobility, and maintaining compliance with PBO requirements. Proactive tax management is essential to mitigate risk and support sustainable growth.

In this issue:

Introduction: Summary of Key Issues

  1. The VAT Conundrum
  2. The Cost of persification

Indirect Taxes: Key Takeaways

  1. Key Tax Risks – VAT

Employees’ Tax & Global Mobility: Key Risks and Recommendations

  1. Remuneration Structure and Employee Benefits
  2. Third Party Service Providers and Contractors
  3. Retirement Benefits, Other Benefits and Allowances
  4. Tax Directives
  5. Global Mobility

International Tax: Permanent Establishment Risk

Corporate Income Tax: Key Risks and Recommendations 

  1. University Subsidiaries
  2. Maintaining PBO Status
  3. Donations and Section 18A Certificates
  4. Transfer of Assets and Capital Gains

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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