Taxpayers often refine their grounds and arguments as a tax dispute progresses. The Western Cape Division of the High Court...
Changing course during a tax dispute
read more
General tax matters
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....
Relief for SA tax residents who incur foreign taxes
South Africa has a residence-based income tax system. This means South African tax residents are subject to income tax on all...
The MLI comes into effect for South Africa
Action 15 of the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (‘BEPS’) required the development of a...
The importance of a thorough objection
The first step for an aggrieved taxpayer to dispute a tax assessment is generally to lodge an objection in terms of section 104...
When is SARS out of time to raise an assessment?
Tax assessments must reach finality. For taxpayers this happens when SARS can no longer issue additional assessments for the...