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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...
When do you need to look further than the transaction’s label? The Meiring Citrus case
Does the label on a contract determine its tax consequences? The Western Cape High Court considered this question in CSARS v Meiring Citrus (Pty) Ltd (A161/2025, 26 June 2026). The judgment deals with a product that was called insurance but, in the court's...
Documentation to support a zero-rating: Interpretation Note 31 (Issue 5)
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...
The taxation of crypto assets
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...
What is section 42 not?
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 may not...
What is section 42?
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...
To charge interest or not?
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...
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