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What is your South African tax residence status?
Many South Africans leave the country. Some do so permanently, while others temporarily work and gain experience abroad. These persons often grapple with the question whether they are still considered to be South African tax residents. SARS recently added guidance on...
Diesel rebates: Lessons from recent cases
Taxpayers conducting operations in certain industries may claim a refund of the road accident fund levies included in the price they paid for fuel used in those activities. The Gauteng High Court recently issued judgments in disputes involving these refunds in...
Responding to SARS requests for information
SARS’ investigative process includes requesting information from taxpayers. In February 2024, the Western Cape High Court delivered judgment in CSARS v J Company. This case deals with requests for relevant material. This article considers the requirements...
Changing course during a tax dispute
Taxpayers often refine their grounds and arguments as a tax dispute progresses. The Western Cape Division of the High Court recently considered such a change in Baseline Civil Contractors (Pty) Ltd v CSARS. This article briefly reviews the case and what other...
Transfer pricing in South Africa: An arm’s length principle case
There have been few transfer pricing-related tax cases in South Africa. They mainly dealt with technicalities of section 31 of the Income Tax Act (‘the ITA’). However, a recent tax court case deals with applying the arm’s length principle, which is at the heart of...
CFCs: The FBE exemption and outsourcing
South Africa introduced controlled foreign company (‘CFC’) rules when it adopted a residence-based tax system in 2001. These rules target passive or mobile income that escapes South African tax by accruing or diverting it to offshore companies controlled by...
VAT Apportionment: Revised ruling
Registered VAT vendors can deduct input tax in respect of goods and services supplied to them. However, they may only deduct such input tax only if, or to the extent, that they acquired goods or services to use, consume or supply in the course of making taxable...
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