Groups of companies often pay expenses on behalf of other group entities, or incur costs centrally and recharge them. The Tax...
Section 11(a) deductions when one group company pays the expenses of another
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Corporate and business tax
Dividend stripping, the GAAR and USPs
In July 2026, the Tax Court handed down judgment in Company AF (Pty) Ltd and Others v Commissioner for the South African...
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...