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VAT on leasehold improvements: a new cost for lessors who are not VAT vendors

VAT on leasehold improvements: a new cost for lessors who are not VAT vendors

by Pieter van der Zwan | Nov 12, 2026 | Amendments, Value Added Tax

Most tax practitioners know the income tax treatment of leasehold improvements well. However, the VAT treatment is less familiar. The 2026 Taxation Laws Amendment Bill (the TLAB) changes the VAT rules for leasehold improvements. The change affects lessors who are not...
Changes to provisional tax underestimation penalty: IPR6 vs payments

Changes to provisional tax underestimation penalty: IPR6 vs payments

by Pieter van der Zwan | Nov 4, 2026 | Amendments, General tax matters

Most taxpayers, and all tax practitioners, deal with provisional tax twice a year. The Tax Administration Laws Amendment Bill (the TALAB) published on 21 October 2026 changes the underestimation penalty on the second provisional tax payment. In this article, I briefly...
Domestic transfer pricing in South Africa: section 31 now applies to SEZ companies

Domestic transfer pricing in South Africa: section 31 now applies to SEZ companies

by Pieter van der Zwan | Nov 3, 2026 | Amendments, Corporate and business tax

In South Africa, transfer pricing is associated with international transactions. That is not unreasonable, because the title of section 31 of the Income Tax Act (the ITA) itself refers to international transactions. The Taxation Laws Amendment Bill (the TLAB)...
Section 11(a) deductions when one group company pays the expenses of another

Section 11(a) deductions when one group company pays the expenses of another

by Pieter van der Zwan | Oct 21, 2026 | Corporate and business tax, General tax matters

Groups of companies often pay expenses on behalf of other group entities, or incur costs centrally and recharge them. The Tax Court recently considered whether a company could deduct the operating costs of an associated mining company that it paid under a contractual...
Remittance of a percentage-based penalties: why requests fail and where the case is made

Remittance of a percentage-based penalties: why requests fail and where the case is made

by Pieter van der Zwan | Oct 17, 2026 | General tax matters

Most taxpayers know of or have experienced the 10% penalty that SARS imposes for the late payment of VAT, employees’ tax or provisional tax. These percentage-based penalties are imposed under section 213 of the Tax Administration Act 28 of 2011 (‘the...
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