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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General tax matters
Changing course during a tax dispute
Taxpayers often refine their grounds and arguments as a tax dispute progresses. The Western Cape Division of the High Court...
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...