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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...
Income tax verification: Assessed losses
SARS did away with the IT14 supplementary declaration for companies (IT14SD) in September 2022. It replaced that declaration with a letter that requests supporting documents based on the reason for the verification. This article considers a recurring request to...
Budget 2023: Tax proposals
The Budget 2023 sets out the National Treasury’s proposals for tax amendments in the 2023 legislative cycle. This article briefly considers a selection of proposals. Energy incentives The Budget Review proposes two incentives to encourage private energy...
Intra-group loans: Tax complexities
Interpretation note on intra-group loans SARS recently published Interpretation Note 127 (‘IN127’). It mainly deals with applying the arm’s length principle to intra-group loans, as the transfer pricing rules require. This complex area requires consideration of,...
The MLI comes into effect for South Africa
Action 15 of the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (‘BEPS’) required the development of a multilateral instrument (‘MLI’). This instrument allows countries to modify existing bilateral tax treaties synchronously and efficiently to...
New tax rules for returns of capital
The National Treasury published the Taxation Laws Amendment Bill for 2022 on 26 October 2022. Amongst others, this bill includes an amendment that affects returns of capital. This is the outcome of a process that started in 2021. Principles of returns of capital When...
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