In July 2026, the Tax Court handed down judgment in Company AF (Pty) Ltd and Others v Commissioner for the South African...
Dividend stripping, the GAAR and USPs
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Amendments
Correcting errors on tax returns – USP risks
The amendments at the end of 2025 affected section 222 of the Tax Administration Act 28 of 2011 (the TAA). The amendment moved...
2026 draft TALAB: PAYE for foreign employers, provisional tax penalties and VDP interest relief
The National Treasury published the 2026 draft Tax Administration Laws Amendment Bill (‘TALAB’) at the end of July 2026. It...
Proposed changes to the taxation of preference shares
The National Treasury published the draft tax law amendment bills for comment on 16 August 2025. A significant proposal relates...
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...
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...