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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 99 prescription: When can SARS reopen a tax assessment?
Section 99 of the Tax Administration Act (the TAA) limits the period within which SARS can raise additional assessments. The Western Cape High Court recently tested those limits in CSARS v Meiring Citrus (Pty) Ltd. In this article, I set out the court's approach...
2026 draft TALAB: PAYE for foreign employers, provisional tax penalties and VDP interest relief
The National Treasury published the 2026 draft Tax Administration Laws Amendment Bill (‘TALAB’) at the end of July 2026. It contains administrative changes that reach beyond the Tax Administration Act. In this article, I discuss three proposals in the draft TALAB....
2026 draft TLAB: Key changes for businesses
The National Treasury has published the 2026 draft tax bills for comment. The bills consist of the draft Taxation Laws Amendment Bill (TLAB) and the draft Tax Administration Laws Amendment Bill (TALAB). They contain the proposals for changes in South African tax...
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...
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