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...
by Pieter van der Zwan | May 20, 2026 | Corporate and business tax, General tax matters, Uncategorized
The general anti-avoidance rules (GAAR) in sections 80A to 80L of the Income Tax Act 58 of 1962 (the Income Tax Act) have featured in several recent judgments. The Constitutional Court has now delivered its judgment on two legal questions raised in the ABSA case....
by Pieter van der Zwan | May 8, 2026 | Corporate and business tax, General tax matters
Section 10(1)(e) of the Income Tax Act 58 of 1962 (the ITA) exempts levy income received by bodies corporate, share block companies and certain voluntary associations from normal tax. SARS released Issue 5 of Interpretation Note 64 in December 2025. The expanded note...
