by Pieter van der Zwan | Sep 25, 2026 | Corporate and business tax
The 2013 Taxation Laws Amendment Act introduced section 23M into the Income Tax Act. This was around the time of the OECD BEPS project and its Action 4, which deals with limitations on interest deductibility. Most early commentary placed it alongside thin...
by Pieter van der Zwan | Sep 16, 2026 | Amendments, General tax matters
The amendments at the end of 2025 affected section 222 of the Tax Administration Act 28 of 2011 (the TAA). The amendment moved the bona fide inadvertent error ground for relief from understatement penalties (USPs) to a different place in the USP regime. The practical...
by Pieter van der Zwan | Sep 9, 2026 | Corporate and business tax, General tax matters
Over the last few months, I have helped several companies prepare RA01 submissions for reportable transactions. I have noticed that advisers either forget about reportable arrangements, or accountants often only realise they should have been reported when they prepare...
by Pieter van der Zwan | Sep 3, 2026 | Corporate and business tax, General tax matters
Are premiums paid in respect of self-insurance products deductible for income tax purposes? In C:SARS v Meiring Citrus (Pty) Ltd (A161/2025), the Western Cape High Court considered this question. I discuss the two elements on which the court decided on the merit of...
by Pieter van der Zwan | Sep 1, 2026 | Corporate and business tax, General tax matters
Section 99 of the Tax Administration Act (the TAA) limits the period within which SARS can raise additional assessments. The Western Cape High Court recently tested those limits in CSARS v Meiring Citrus (Pty) Ltd. In this article, I set out the court’s...
