South Africa: Tax

South Africa's tax landscape is evolving with new border control requirements, refined R&D incentives, and recent SARS rulings on mining rehabilitation and equity structures. What do these developments mean for businesses operating across borders and claiming tax relief?

The 2025 Update to the OECD Model Tax Convention Commentaries provides guidance on when a home or remote location can give rise to a fixed place of business PE under Article 5(1).

On 29 April 2025, the African Tax Administration Forum ("ATAF") announced that it has commenced a review of its ATAF Income Model Convention (2019), aimed at strengthening the ability of African countries to negotiate tax...

Estate planning extends far beyond drafting a valid Will. This article examines the critical but often overlooked issue of estate liquidity—the availability of cash to settle taxes, debts, and administration costs—and explains why asset-rich estates can still face serious financial challenges during administration.

In South Africa, we are privileged not to have to pay inheritance tax on the benefits received from a deceased estate. In many countries such as the United Kingdom citizens must pay an inheritance tax...

The most significant proposals in the 2018 Budget Review will probably affect all taxpayers in South Africa, not only those with accumulated wealth.

SARS has announced the filing dates for the 2026 tax season which will open 13 July 2026. We remind all clients that, as tax residents, you are required to declare your worldwide income, not just amounts earned locally in South Africa. This includes earnings from foreign employment, investments, rental income, and any offshore structures. For those taxpayers who choose (or have previously chosen) not to disclose, this decision will not be without consequences. Why?

This issue of ENS' tax in brief provides a comprehensive snapshot of the latest tax developments in South Africa, covering recent case law on VAT apportionment methods, newly published draft taxation bills, income tax notices regarding double taxation agreement advance pricing agreements, and significant updates from SARS including guidance on employment tax incentives and VAT deregistration requirements for schools.

The Western Cape High Court's recent ruling in C:SARS v Meiring Citrus overturned a Tax Court decision and disallowed a ZAR9.6 million income tax deduction claimed by a citrus farmer for what was marketed as an insurance premium. The judgment raises critical questions about the distinction between genuine insurance and investment arrangements, the burden of proof in prescription cases, and the application of accounting standards to tax deductions. Taxpayers with similar structured self-insurance products sh

Cross-border tax compliance between Botswana and South Africa is undergoing significant transformation as SARS deploys AI-driven enforcement tools, Botswana proposes a shift to residence-based taxation, and global minimum...

This issue of ENS' tax in brief provides a comprehensive snapshot of recent South African tax developments, including significant High Court judgments on SARS appeals and enforcement orders, new SARS publications on documentary proof requirements and the Advance Pricing Agreement programme, and multiple customs and excise tariff amendments affecting various imported goods. The brief also covers important international developments from the OECD regarding the Global Minimum Tax implementation and corporate t

This comprehensive update covers significant tax and regulatory developments across 30 African jurisdictions during mid-2026, including Angola's new oil block incentives and unified Personal Income Tax Code, Botswana's major tax rate increases and transfer pricing regulations, Kenya's Finance Act 2026 with mortgage interest relief expansion, Nigeria's implementation of the unified Taxpayer Identification system and presumptive tax regime, and Rwanda's new transfer pricing rules framework. The bulletin exami