South Africa: Income Tax

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

ENS presents issue 171 of its tax brief, covering recent South African tax developments including significant Supreme Court and Tax Court judgments on import duties, dividend stripping arrangements, and insurance contract deductions. The brief also details new SARS filing requirements, updated guides for the 2026 filing season, and important changes to customs procedures and VAT treatment of ambulance services.

Issue 164 of ENS' tax in brief, a snapshot of the latest tax developments in South Africa.

The transition from the Johannesburg Interbank Average Rate (JIBAR) to the South African Rand Overnight Index Average (ZARONIA)...

On 6 February 2026, the Africa Tax Administration Forum ("ATAF") published a Technical Note summarising changes to the Global Minimum Tax ("GMT"), referred to as a "Side-by-Side Package".

Buying or selling a property in South Africa is not just about signing a contract, it is a legal and financial journey that involves a range of professionals...

South Africa's recent amendment to section 25B of the Income Tax Act introduces a material change in the taxation of income distributed by resident trusts to non-resident beneficiaries.

Section 45 of the Income Tax Act 58 of 1962 (the "ITA") provides a valuable tax deferral mechanism for corporate groups wishing to reorganise their internal structures without incurring immediate tax consequences.