All Articles
Tax consequences of debt relief
Debt restructuring arrangements are likely to become more prevalent in the tough economic conditions that South Africa currently encounter. One of the key considerations when entering into such an arrangement is to understand the tax consequences. This article...
Telkom case: Exchange losses on shareholder loans
The Supreme Court of Appeal (‘the SCA’) delivered judgment in Telkom SA SOC Limited v C:SARS (Case no 239/19) [2020] ZASCA 19 on 25 March 2020. One of the matters considered in this case related to a deduction claimed by Telkom SA SOC Ltd (‘Telkom’) in respect of...
Tax proposals in the 2020 Budget Review
The National Treasury published its annual Budget Review on 26 February 2020 (‘the Budget Review’). The above-inflation proposed adjustments to the progressive tax brackets, rather than anticipated increases in tax rates, surprised many commentators. Chapter 4 and...
Timing of tax deductions for customer loyalty scheme costs
Section 24C of the Income Tax Act provides an allowance for certain obligations to incur expenditure in future. The Supreme Court of Appeal (SCA) delivered its judgment in the matter between C:SARS v Clicks Retailers (Pty) Ltd (‘the Clicks case’), which related to the...
Broadened anti-dividend stripping tax rules
The National Treasury announced in the 2019 Budget Review that the anti-dividend stripping rules will be amended to apply to certain dilutive arrangements that undermined these rules. The Taxation Laws Amendment Bill of 2019, which was introduced in Parliament on 30...
The amended foreign employment income exemption
Since 2000, when South Africa changed from a source-based to a residence-based tax system, South African residents earning employment income for services rendered outside South Africa enjoyed an exemption of such income if: the person spend more than 183 days outside...
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