South Africa: Corporate 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
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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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