All Articles
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...
Trusts: Conduit-pipe tax rules
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
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 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
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...
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