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Assumption of contingent liabilities in restructuring transactions
The Income Tax Act contains a number of special rules, often referred to as the corporate rules, to facilitate certain restructuring arrangements in a tax neutral manner. These rules were amended in 2017 by the addition of a definition of debt, which specifically...
VAT: Separation of supplies into parts
Where a supply consists of parts that would be subject to different VAT rates if consideration had been charged separately for each part, the VAT Act requires that such parts be treated as separate supplies (section 8(15) of the VAT Act). This article briefly reviews...
Budget 2019: Business and corporate tax perspective
The National Treasury published the Budget Review 2019 (‘BR2019’) on 20 February 2019. No significant adjustments were made to tax rates and the general perception of commentators appears rule to be that the BR2019 was less eventful from a tax perspective than in...
Deductions allowed for future expenditure
Taxpayers are taxed on income at the earlier of the date of receipt or accrual and are entitled to deduct expenditure to produce this income when such expenditure has been incurred. While the these two sets of events may in some instances fall in the same year of...
Timing of accrual of proceeds from cash sales of property
A taxpayer is generally taxed on amounts at the earlier of accrual or receipt of those amounts. If one looks back at case law over the years, the timing of accrual of amounts has often been a contentious matter. The recent judgment in Milnerton Estates Ltd v CSARS in...
Amendments to the debt relief tax rules
The Income Tax Act contains specific rules that determine the tax implications if a taxpayer is relieved of its debts obligations. These rules were significantly amended during the 2017 legislative cycle. The National Treasury acknowledged various concerns with the...
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