The appellate division established the conduit-pipe principle in 1938 in Armstrong v CIR and confirmed it in subsequent cases....
Trusts: Conduit-pipe tax rules
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Individuals and wealth planning
Employee share schemes: South African tax considerations
Companies often set up employee share schemes that incentivise and align key staff members with the company’s broader...
Tax implications of emigrating from South Africa
An estimated 20 000 to 25 000 South Africans emigrate from the country every year. The current trend is that this number is...
Budget 2023: Tax proposals
The Budget 2023 sets out the National Treasury’s proposals for tax amendments in the 2023 legislative cycle. This article...
What is your South African tax residence status?
Many South Africans leave the country. Some do so permanently, while others temporarily work and gain experience abroad. These...
The mechanics of asset-for-share transactions
Asset-for-share transactions qualify for relief under the corporate rule in section 42 of the Income Tax Act (‘the ITA’). In the...