The National Treasury published the draft tax law amendment bills for comment on 16 August 2025. A significant proposal relates...
Proposed changes to the taxation of preference shares
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Corporate and business tax
Transfer pricing in South Africa: An arm’s length principle case
There have been few transfer pricing-related tax cases in South Africa. They mainly dealt with technicalities of section 31 of...
CFCs: The FBE exemption and outsourcing
South Africa introduced controlled foreign company (‘CFC’) rules when it adopted a residence-based tax system in 2001....
Trusts: Conduit-pipe tax rules
The appellate division established the conduit-pipe principle in 1938 in Armstrong v CIR and confirmed it in subsequent cases....
Relief for SA tax residents who incur foreign taxes
South Africa has a residence-based income tax system. This means South African tax residents are subject to income tax on all...
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...