South Africa: Corporate Tax

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Article
The Diesel Refund Scheme: Wet And Dry Contracts, Joint Ventures And New Ways Of Mining In South Africa
South Africa's diesel refund scheme has long provided fiscal relief to mining operations, but its legislative framework struggles to accommodate modern contractual arrangements like wet contracts and joint ventures. Recent Supreme Court of Appeal judgments and 2022 amendments are reshaping how mining companies can access these vital refunds, though significant gaps remain between commercial reality and legal requirements.
South Africa Tax
E
ENS
Article
Africa Tax In Brief
African nations are implementing sweeping tax reforms across multiple jurisdictions, from Angola's supplementary petroleum incentives and Nigeria's virtual asset taxation framework to Mauritius's digital marketplace VAT rules and the Democratic Republic of the Congo's mining royalty adjustments. These coordinated changes reflect a continent-wide effort to modernize revenue collection, expand digital taxation, and strengthen compliance mechanisms.
South Africa Tax
E
ENS
Article
Binding Private Ruling 430 And Trust-to-trust Distributions
South Africa's Revenue Service has issued Binding Private Ruling 430, clarifying its position on trust-to-trust distributions and the section 7(8) attribution rules. The ruling examines whether distributing an interest-free loan claim constitutes a disposition, explores how the causal nexus can be severed when downstream yields are generated by independent foreign companies, and reveals the administrative complexities trustees face when claiming foreign tax rebates for non-resident beneficiaries.
South Africa Tax
CD
Cliffe Dekker Hofmeyr
Article
The Robot Did The Work. Now Who Pays The Tax?
As artificial intelligence increasingly performs tasks once carried out by human workers, governments face a fundamental challenge: tax systems designed around employment-based revenue are under pressure. With more economic value flowing to technology and capital rather than through traditional payroll structures, policymakers must confront difficult questions about how automation should be taxed and whether current incentives inadvertently encourage workforce reduction.
South Africa Commercial
Ai
Andersen in South Africa
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