South Africa: Tax

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Article
Africa Tax In Brief - 14 July 2026
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
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Article
Structured Self-insurance: A Win For SARS, But Questions Remain
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
South Africa Tax
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Article
Tax Court Applies The GAAR To Dividend Stripping: Companies AF (Pty) Ltd And Others v C:SARS
The Tax Court in Cape Town has ruled on a dividend stripping arrangement used in the sale of a self-storage business, applying South Africa's general anti-avoidance rules to a structure where shareholders attempted to convert taxable capital gains into exempt intercompany dividends. Following the Constitutional Court's recent decision in Absa Bank Ltd v SARS, the Court examined whether a pre-acquisition dividend funded by the purchaser's subscription served any purpose beyond tax avoidance, and whether the
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Article
Structured Self-insurance: A Win For SARS, But Questions Remain
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
South Africa Tax
E
ENS
Article
Africa Tax In Brief
ENS's Tax in Brief Issue 170 delivers a comprehensive snapshot of South Africa's evolving tax landscape, covering a landmark Constitutional Court ruling on VAT zero-rating for recycled gold, new draft regulations on domestic reverse charge mechanisms for valuable metals, and critical updates to PAYE reconciliation requirements. The bulletin also examines SARS's implementation of Global Minimum Tax returns, Filing Season 2026 enhancements, and significant customs and excise amendments including China's Zero-
South Africa Tax
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ENS
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Article
Africa Tax In Brief - 14 July 2026
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
Worldwide Tax
E
ENS
Article
Africa Tax In Brief
The African Tax Administration Forum and OECD have concluded transfer pricing workshops for Francophone tax officials, while multiple African nations implement significant tax reforms including VAT changes, e-invoicing requirements, and new compliance measures. From Kenya's reduced petroleum VAT rates to Liberia's comprehensive tax amendments and Uganda's proposed alternative minimum tax, these developments reflect a continent-wide effort to modernize tax administration and enhance revenue collection.
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