by Pieter van der Zwan | Aug 5, 2026 | Value Added Tax
SARS has issued a new version of Interpretation Note 31. Issue 5 replaces Issue 4, which was issued in 2016. The note sets out the documentation SARS accepts as proof that a zero-rating applies. This article discusses some critical aspects of zero-rating and changes...
by Pieter van der Zwan | Jul 22, 2026 | General tax matters
SARS published a draft guide on the taxation of crypto assets in early July. Although it is not binding, even once finalised, it shows SARS’s position on the tax treatment of crypto assets. In this article, I consider some of SARS’ views in the draft guide. Capital or...
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...
