The number of cases before South African courts involving the general anti-avoidance rules (the GAAR) have increased noticeably...
Be careful of the GAAR
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Corporate and business tax
Pointers for share incentive schemes
Many companies use share incentive schemes to align the objectives of key staff members and the company. The design may look...
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....