Proposed changes to the taxation of preference shares

The National Treasury published the draft tax law amendment bills for comment on 16 August 2025. A significant proposal relates to section 8E, which deals with hybrid equity instruments. It affects, amongst others, preference shares. In this episode of my podcast, Tax Break, I discuss the proposed changes and share my initial thoughts about it.

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What is your South African tax residence status?

Sep 7, 2021 | Individuals and wealth planning

Many South Africans leave the country. Some do so permanently, while others temporarily work and gain experience abroad. These persons often grapple with the question whether they are still considered to be South African tax residents. SARS recently added guidance on...

Trusts – good or bad?

Aug 1, 2025 | Individuals and wealth planning

One of the most popular episodes of my podcast, Tax Break, deals with a question that often comes up from advisors: this is whether they should advise their clients to keep their assets in trusts. This depends on the facts and circumstances of each case and some tax...

Diesel rebates: Lessons from recent cases

Feb 14, 2025 | Value Added Tax

Taxpayers conducting operations in certain industries may claim a refund of the road accident fund levies included in the price they paid for fuel used in those activities. The Gauteng High Court recently issued judgments in disputes involving these refunds in...

Responding to SARS requests for information

Sep 15, 2024 | Uncategorized

SARS’ investigative process includes requesting information from taxpayers. In February 2024, the Western Cape High Court delivered judgment in CSARS v J Company. This case deals with requests for relevant material. This article considers the requirements...

Changing course during a tax dispute

Sep 15, 2024 | General tax matters

Taxpayers often refine their grounds and arguments as a tax dispute progresses. The Western Cape Division of the High Court recently considered such a change in Baseline Civil Contractors (Pty) Ltd v CSARS. This article briefly reviews the case and what other...

Transfer pricing in South Africa: An arm’s length principle case

Sep 15, 2024 | Corporate and business tax

There have been few transfer pricing-related tax cases in South Africa. They mainly dealt with technicalities of section 31 of the Income Tax Act (‘the ITA’). However, a recent tax court case deals with applying the arm’s length principle, which is at the heart of...

CFCs: The FBE exemption and outsourcing

Jun 28, 2024 | Corporate and business tax

South Africa introduced controlled foreign company (‘CFC’) rules when it adopted a residence-based tax system in 2001. These rules target passive or mobile income that escapes South African tax by accruing or diverting it to offshore companies controlled by...

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