In July 2026, the Tax Court handed down judgment in Company AF (Pty) Ltd and Others v Commissioner for the South African Revenue...
Dividend stripping, the GAAR and USPs
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Corporate and business tax
Section 23M interest limitation: when does it apply?
The 2013 Taxation Laws Amendment Act introduced section 23M into the Income Tax Act. This was around the time of the OECD BEPS...
Is a transaction a reportable arrangement?
Over the last few months, I have helped several companies prepare RA01 submissions for reportable transactions. I have noticed...
Are self-insurance premiums deductible?
Are premiums paid in respect of self-insurance products deductible for income tax purposes? In C:SARS v Meiring Citrus (Pty) Ltd...
Section 99 prescription: When can SARS reopen a tax assessment?
Section 99 of the Tax Administration Act (the TAA) limits the period within which SARS can raise additional assessments. The...
2026 draft TLAB: Key changes for businesses
The National Treasury has published the 2026 draft tax bills for comment. The bills consist of the draft Taxation Laws Amendment...