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Trusts: Conduit-pipe tax rules

Trusts: Conduit-pipe tax rules

by Pieter van der Zwan | Feb 8, 2024 | Corporate and business tax, General tax matters, Individuals and wealth planning

The appellate division established the conduit-pipe principle in 1938 in Armstrong v CIR and confirmed it in subsequent cases. If this principle applies, the beneficiary entitled to the trust income is liable for tax on the income. Section 25B of the Income Tax Act,...
Relief for SA tax residents who incur foreign taxes

Relief for SA tax residents who incur foreign taxes

by Pieter van der Zwan | Feb 1, 2024 | Corporate and business tax, General tax matters

South Africa has a residence-based income tax system. This means South African tax residents are subject to income tax on all their income, irrespective of the source. Both South Africa and another country, therefore, often tax income arising abroad. The Income Tax...
Section 12BA: 125% allowance on renewable energy assets

Section 12BA: 125% allowance on renewable energy assets

by Pieter van der Zwan | Nov 12, 2023 | Amendments, Corporate and business tax

Section 12B provides a 100% deduction for assets that a taxpayer uses in the generation of electricity from PV solar energy not exceeding 1 MW. It has allowed this since 2015. In the 2023 Budget Review, the National Treasury announced a temporary expansion of the...
Employee share schemes: South African tax considerations

Employee share schemes: South African tax considerations

by Pieter van der Zwan | Oct 11, 2023 | Corporate and business tax, Individuals and wealth planning

  Companies often set up employee share schemes that incentivise and align key staff members with the company’s broader objectives. As with any remuneration, these schemes have tax implications for the employer and employee. This article provides a high-level...
Tax implications of emigrating from South Africa

Tax implications of emigrating from South Africa

by Pieter van der Zwan | Sep 29, 2023 | Individuals and wealth planning

An estimated 20 000 to 25 000 South Africans emigrate from the country every year. The current trend is that this number is increasing. The reasons and circumstances for South Africans emigrating vary for each individual or family. Factors such as a lack of employment...
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