All Articles
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...
The importance of a thorough objection
The first step for an aggrieved taxpayer to dispute a tax assessment is generally to lodge an objection in terms of section 104 of the Tax Administration Act (the TAA). In this article, I consider The Commissioner for the South African Revenue Service v Airports...
Tax treatment of costs to raise funding
There are many costs to raise funding for a business, whether debt or equity capital. These include raising fees, initiation fees, facility fees and charges relating to structuring the transaction, to mention a few. In this article, I consider a recent case that dealt...
VAT proposals for 2022
VAT vendors can expect a number of amendments that affect specific classes of vendors in 2023. The National Treasury published the draft Taxation Laws Amendment Bill (‘TLAB’) for comment on 29 July 2022. It contains a number of proposals for amendments to the Value...
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