by Pieter van der Zwan | Jul 16, 2026 | Corporate and business tax, Individuals and wealth planning
Section 42 of the Income Tax Act often features in restructuring discussions or proposals. When considering transactions or restructurings involving section 42 of the Income Tax, it is important to understand the provision’s boundaries. In other words, when it...
by Pieter van der Zwan | Jul 7, 2026 | Corporate and business tax, General tax matters
Taxpayers and their advisors employ section 42 of the Income Tax Act in various types of transactions. When encountering this provision, it is important to understand its mechanics but also its broader context. In this article, I discuss the some of the background to...
by Pieter van der Zwan | Jun 22, 2026 | Corporate and business tax, General tax matters, Individuals and wealth planning
The question often arises whether the tax law obliges certain lenders to charge interest on loans to connected parties. This includes loans between natural persons and a family trust or a company and its shareholders. The answer is arguably that the tax law never...
by Pieter van der Zwan | Jun 9, 2026 | Corporate and business tax, General tax matters
One often encounters arguments that the year in which something is taxed or deducted does not really matter: as long as SARS taxes the amount or a deduction is claimed only once, the fiscus suffers no real loss. This position is, of course, not correct. A recent...
by Pieter van der Zwan | May 25, 2026 | Uncategorized
On 19 May 2026, SARS published guidance on the new Beneficial Owner Register for Partnerships (IT3(BO)). This process involves a designated partnership representative submitting a single annual declaration of the partnership and partner information. This replaces the...
