All Articles
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...
Tax implications of emigrating from South Africa
An estimated 20 000 to 25 000 South Africans emigrate from the country every year. The current trend is that this number is increasing. The reasons and circumstances for South Africans emigrating vary for each individual or family. Factors such as a lack of employment...
Proposal to cushion Practice Note 31’s withdrawal
The National Treasury published the draft Taxation Laws Amendment Bill for the 2023 legislative cycle on 31 July 2023. It contains a proposal that relates to the withdrawal of Practice Note 31 of 1994 (‘PN31’). This article considers the background and proposed...
Place of effective management: SARS’ views
Place of effective management (‘POEM’) is critical in determining the South African tax residence of persons other than natural persons. SARS recently published Issue 3 of Interpretation Note 6 (‘IN6’), which deals with POEM. This article considers the continued...
Input tax: Holding companies
Vendors may deduct input tax on goods or services acquired for purposes of making taxable supplies in the course of furtherance of their enterprise. This article considers a recent tax court judgment (case 1922) that dealt with input tax deducted by a...
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