Many companies use share incentive schemes to align the objectives of key staff members and the company. The design may look...
Pointers for share incentive schemes
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Corporate and business tax
Dividend or donation?
If a company makes payments to a related party of its shareholder, the question arises whether this is a dividend, or perhaps...
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...
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....