The National Treasury has published the 2026 draft tax bills for comment. The bills consist of the draft Taxation Laws Amendment...
Corporate and business tax
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What is section 42 not?
Section 42 of the Income Tax Act often features in restructuring discussions or proposals. When considering transactions or...
What is section 42?
Taxpayers and their advisors employ section 42 of the Income Tax Act in various types of transactions. When encountering this...
To charge interest or not?
The question often arises whether the tax law obliges certain lenders to charge interest on loans to connected parties. This...
The timing of tax deductions matters
One often encounters arguments that the year in which something is taxed or deducted does not really matter: as long as SARS...
The ABSA case: “Party” and “Tax Benefit” under the GAAR
The general anti-avoidance rules (GAAR) in sections 80A to 80L of the Income Tax Act 58 of 1962 (the Income Tax Act) have...






