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 to section 8E, which deals with hybrid equity instruments. It affects, amongst others, preference shares. In this episode of my podcast, Tax Break, I discuss the proposed changes and share my initial thoughts about it.

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What is your South African tax residence status?

Sep 7, 2021 | Individuals and wealth planning

Many South Africans leave the country. Some do so permanently, while others temporarily work and gain experience abroad. These persons often grapple with the question whether they are still considered to be South African tax residents. SARS recently added guidance on...

Is a transaction a reportable arrangement?

Sep 9, 2026 | Corporate and business tax, General tax matters

Over the last few months, I have helped several companies prepare RA01 submissions for reportable transactions. I have noticed that advisers either forget about reportable arrangements, or accountants often only realise they should have been reported when they prepare...

Are self-insurance premiums deductible?

Sep 3, 2026 | Corporate and business tax, General tax matters

Are premiums paid in respect of self-insurance products deductible for income tax purposes? In C:SARS v Meiring Citrus (Pty) Ltd (A161/2025), the Western Cape High Court considered this question. I discuss the two elements on which the court decided on the merit of...

Section 99 prescription: When can SARS reopen a tax assessment?

Sep 1, 2026 | Corporate and business tax, General tax matters

Section 99 of the Tax Administration Act (the TAA) limits the period within which SARS can raise additional assessments. The Western Cape High Court recently tested those limits in CSARS v Meiring Citrus (Pty) Ltd. In this article, I set out the court's approach...

2026 draft TALAB: PAYE for foreign employers, provisional tax penalties and VDP interest relief

Aug 25, 2026 | Amendments, General tax matters

The National Treasury published the 2026 draft Tax Administration Laws Amendment Bill (‘TALAB’) at the end of July 2026. It contains administrative changes that reach beyond the Tax Administration Act. In this article, I discuss three proposals in the draft TALAB....

2026 draft TLAB: Key changes for businesses

Aug 14, 2026 | Corporate and business tax, General tax matters, Value Added Tax

The National Treasury has published the 2026 draft tax bills for comment. The bills consist of the draft Taxation Laws Amendment Bill (TLAB) and the draft Tax Administration Laws Amendment Bill (TALAB). They contain the proposals for changes in South African tax...

When do you need to look further than the transaction’s label? The Meiring Citrus case

Aug 10, 2026 | General tax matters

Does the label on a contract determine its tax consequences? The Western Cape High Court considered this question in CSARS v Meiring Citrus (Pty) Ltd (A161/2025, 26 June 2026). The judgment deals with a product that was called insurance but, in the court's...

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