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...
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...
by Pieter van der Zwan | Oct 7, 2026 | Amendments, Corporate and business tax
In July 2026, the Tax Court handed down judgment in Company AF (Pty) Ltd and Others v Commissioner for the South African Revenue Service [2026] ZATC. The judgment deals with the application of the general anti-avoidance rule (the GAAR) in sections 80A to 80L...
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...
