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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...
Section 11(a) deductions when one group company pays the expenses of another
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...
Remittance of a percentage-based penalties: why requests fail and where the case is made
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 TAA'). From time...
Dividend stripping, the GAAR and USPs
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...
Section 23M interest limitation: when does it apply?
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...
Correcting errors on tax returns – USP risks
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...
Is a transaction a reportable arrangement?
Over the last few months, I have helped several companies prepare RA01 submissions for reportable transactions. I have noticed that advisers either forget about reportable arrangements, or accountants often only realise they should have been reported when they prepare...
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