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Corporate Tax News

Navigating the enhanced section 11D R&D incentive

21 October 2025
Corporate Tax

The Section 11D R&D tax incentive, outlining recent legislative changes, eligibility criteria, quali...

Vehicle Fringe Benefits in a CC: South African Tax...

21 July 2025
Corporate Tax

Two Close Corporation (CC) members use vehicles registered in the CC’s name solely for private purpo...

Deferred Tax: The Quiet Complexity Lurking in Fina...

16 July 2025
Corporate Tax

Deferred tax is more than an accounting issue—it impacts financial clarity and tax compliance. This...

Are Veterinary Inspection Fund Fees Deductible for...

25 June 2025
Corporate Tax

This article explains whether farmers can deduct veterinary inspection fees as a business expense or...

FICA Compliance for Tax Practitioners: Are You at...

25 June 2025
Corporate Tax

Tax Practitioners: If you offer tax advisory services, you may be an Accountable Institution under F...

Setting Legal and Market-Related Interest Rates on...

20 May 2025
Corporate Tax

The question addresses how to determine a compliant interest rate on loans to related corporate shar...

ITR14 Under Scrutiny: Why SARS Is Watching—and How...

22 May 2025
Corporate Tax

SARS is tightening its grip on corporate tax compliance, with increased audits and penalties linked...

The Tax Treatment of Goodwill: Why Amortisation is...

15 April 2025
Corporate Tax

A brief overview of why goodwill amortisation is not tax-deductible under South African income tax l...

Solar Tax Incentive – Wear and Tear Clarification

27 January 2025
Corporate Tax

Businesses can claim a 125% tax deduction on new, qualifying solar assets under Section 12BA, valid...

Clarification on Section 64E(4) and Credit Loan Ac...

28 January 2025
Corporate Tax

Seeking clarification on the application of Section 64E(4) to credit loan accounts, potential donati...

Tax Deductibility of Loan Waiver Upon Employee Res...

12 March 2025
Corporate Tax

Assessing the tax deductibility of a loan waiver and related tax liabilities paid by an employer fol...

Tax Treatment of R10M Land Sale Error

06 January 2025
Corporate Tax

A client seeks advice on addressing tax issues with SARS after R10 million from a land sale was inco...

Tax Tech is Evolving Faster Than Ever: Why Staying...

28 January 2025
Corporate Tax

Have you noticed how rapidly the world of tax technology is transforming? Just a few years ago, the...

7 Essential Tax Strategies for Small Business Succ...

06 August 2024
Corporate Tax

Essential tax strategies for small business owners, emphasising the importance of tax risk managemen...

Reliance on an Opinion to Mitigate Understatement...

05 August 2024
Corporate Tax

One of the most daunting questions for a taxpayer who is issued with an understatement penalty asses...

Voluntary Disclosure Programme - Voluntary or Not?

02 August 2024
Corporate Tax

Two of the fundamental requirements to access the VDP are that the disclosure must be voluntary and...

Three Wishes for Small Business Tax Incentives

24 July 2024
Corporate Tax

The importance of the small business sector in the South African economy is well documented. Small b...

A Collective Sigh of Relief After Coronation Case

24 June 2024
Corporate Tax

Ruling on multimillion-rand tax debt brings an end to anxiety and uncertainty in the market.

NPO - PBO

20 June 2024
Corporate Tax

The concepts of NPO and PBO are not interchangeable. An NPO is regulated by the Department of Social...

Compliance is the New Tax Currency

19 April 2024
Corporate Tax

The Commissioner for SARS is in the process of tightening up tax compliance with a view of breaching...

At it again: Capital v revenue

14 September 2023
Corporate Tax

At it again: Capital v revenue

Practice Note 31’s withdrawal

16 August 2023
Corporate Tax

Practice Note 31’s withdrawal

[FAQ] Small Business Corporation

25 July 2023
Corporate Tax

[FAQ] Small Business Corporation

A more equitable outcome for unbundling transactio...

22 March 2023
Corporate Tax

A more equitable outcome for unbundling transactions

Fine-tuning the debt forgiveness rules for dormant...

22 March 2023
Corporate Tax

Fine-tuning the debt forgiveness rules for dormant group companies

Intra-group loans: Tax complexities

16 February 2023
Corporate Tax

Intra-group loans: Tax complexities

BINDING PRIVATE RULING: BPR 388 - Application of t...

03 February 2023
Corporate Tax

BPR 388 - Application of the de-grouping rule following previous intra-group transactions under sect...

Determination of the Taxable Income of Certain Per...

03 February 2023
Corporate Tax

Determination of the Taxable Income of Certain Persons from International Transactions: Intra-Group...

Application of the de-grouping rule following prev...

16 January 2023
Corporate Tax

Application of the de-grouping rule following previous intra-group transactions under section 45

Check your mirrors: Sticking to original grounds o...

15 November 2022
Corporate Tax

Check your mirrors: Sticking to original grounds of objection in SCA tax appeal proceedings

Another year, another amendment: Timing matters wh...

21 September 2022
Corporate Tax

Another year, another amendment: Timing matters when tax legislation changes

Proposals to increase the carbon tax rate from 202...

13 September 2022
Corporate Tax

Proposals to increase the carbon tax rate from 2023 – 2030: The only way to reduce carbon emissions?

Employer Interim Reconciliation Filing Season

13 September 2022
Corporate Tax

Employer Interim Reconciliation Filing Season

Corporate Income Tax (CIT): Removal of the Supplem...

30 August 2022
Corporate Tax

Corporate Income Tax (CIT): Removal Of The Supplementary Declaration for Companies or Close Corporat...

e@syFile version 7.2.6 (including 7.2.5)

20 May 2022
Corporate Tax

e@syFile version 7.2.6 (including 7.2.5)

The revenue (as opposed to capital) nature of ‘oth...

11 April 2022
Corporate Tax

Oftentimes, when taxpayers secure funding for capital projects, such funding attracts interest as we...

[FAQ] Fees paid to a business rescue practitioner

08 July 2021
Corporate Tax

Are the fees paid to a business rescue practitioner tax deductible?

[FAQ] Tax consequences of loans between group comp...

21 June 2021
Corporate Tax

What are the tax consequences for both Company A and Company B if Company A either capitalizes the l...

[FAQ] Income tax deduction with regards to bursari...

20 May 2021
Corporate Tax

A large corporation wishes to make bursaries available to its staff. They have been approached by a...

[FAQ] Connected persons and the waiver of loans

28 April 2021
Corporate Tax

Two companies with loan accounts between them are connected persons. The one company liquidated duri...

[FAQ] Withholding tax calculation for foreign spor...

21 April 2021
Corporate Tax

Foreign sportspersons are managed by a company in the Netherlands who invoices a South African compa...

[FAQ] The term “consultant” when assessing the S12...

16 April 2021
Corporate Tax

Company C has two sources of income streams – one does recruitment of candidates for the placement a...

[FAQ] The issue of shares as payment for debt

05 March 2021
Corporate Tax

South African Company A paid a supplier for goods delivered directly to Company B(based in Singapore...

[FAQ] The deduction of expenses incurred when taki...

01 February 2021
Corporate Tax

A taxpayer wants to take her staff and their families away for a few days as a team building/thank y...

[FAQ] Shares held as trading stock

01 December 2020
Corporate Tax

A company trades in shares. How will the share value gain be accounted for tax purposes? Would the s...

Notice by SARS where financials were prepared for...

16 November 2020
Corporate Tax

A new company prepared annual financial statements for 15 months which included the 3 months of its...

BCR 075 - Settlement of post-retirement medical a...

13 November 2020
Corporate Tax

This ruling determines the tax consequences for the employers and the qualifying employees due to th...

Relevance of accounting standards to South Africa...

16 September 2020
Corporate Tax

This article considers the relevance of the accounting treatment of transactions for South African t...

BPR 353 – Linear adjustment of gross sales of unre...

14 September 2020
Corporate Tax

This ruling determines that a linear adjustment may be made to adjust gross sales of an unrefined mi...

Estimating the tax effects of the sale of a busine...

27 May 2020
Corporate Tax

Tax practitioners are often asked to calculate the indicative effects of the prospective sale of a b...

Managing exchange of information requests in trans...

05 May 2020
Corporate Tax

Requests for information between tax authorities and requests for taxpayers to supply the informatio...

Covid-19: How to manage 'place of effective manage...

06 May 2020
Corporate Tax

Covid-19 is only anticipated to peak in South Africa (SA) in September 2020, with international air...

Employment Revival Guide – Alert Level 4 Regulatio...

01 May 2020
Corporate Tax

Alert Level 4 of the lockdown is geared toward the revival of economic activities and to allow emplo...

Further tax measures for businesses to combat the...

23 April 2020
Corporate Tax

In line with the President’s address to the nation on 21 April 2020, the Minister of Finance provide...

Tax and Fiscal Policy in Response to the Coronavir...

15 April 2020
Corporate Tax

The OECD released its report on Tax and Fiscal Policy in Response to the Coronavirus Crisis on 15 Ap...

COVID-19: The UIF announces important updates to T...

16 April 2020
Corporate Tax

Many businesses directly or indirectly impacted by the COVID-19 pandemic, have one problem in common...

Proposal regarding COVID-19 disaster relief funds...

03 April 2020
Corporate Tax

In this article the proposal regarding donations made to COVID-19 disaster relief funds is briefly d...

GUIDELINES FOR APPLICATION: DEBT RELIEF FINANCE SC...

28 March 2020
Corporate Tax

For Small Businesses in need of financial support during this difficult time, refer to the Debt Reli...

Case Law: Telkom SA SOC Limited vs The Commissione...

25 March 2020
Corporate Tax

A judgment handed down on March 25 by the Supreme Court of Appeal (SCA) held that a R3.9 billion for...

Covid-19 and Tax

25 March 2020
Corporate Tax

Monday 23 March 2020 will be remembered in the history books as the day that South Africa declared w...

Comparable Tax Exemption (Section 9D(2A))

23 March 2020
Corporate Tax

This amendment determines that the comparable tax exemption threshold be reduced to 67.5%.

Value-Shifting Rules (Section 24BA and Section 40C...

18 March 2020
Corporate Tax

Anti-avoidance principles preventing the transfer of high value assets to a company in return for lo...

Enhancements to the ITR14 Company Income Tax Retur...

21 February 2020
Corporate Tax

On 21 February 2020, SARS implemented enhancements to the ITR14 Company Income Tax Return.

Discussion paper on reviewing the tax treatment o...

26 February 2020
Corporate Tax

Reviewing the Tax Treatment of Excessive Debt Financing, Interest Deductions and Other Financial Pay...

Interpretation Note 44 (Issue 3) – Public Benefit...

21 February 2020
Corporate Tax

This Interpretation Note provides guidance on the application and interpretation of paragraph 63A wh...

SARS Guide on Venture Capital Companies

18 February 2020
Corporate Tax

This guide provides users with general guidance on venture capital companies and investments in such...

Draft Documents for Public Comment: Draft Binding...

13 February 2020
Corporate Tax

The draft BGR provides clarity on what constitutes an unbundling transaction under section 46(1) of...

OECD releases Transfer Pricing Guidance on Financi...

11 February 2020
Corporate Tax

The OECD released the report "Transfer Pricing Guidance on Financial Transactions: Inclusive Framewo...

Interpretation Note 75 (Issue 3) – Exclusion of ce...

11 February 2020
Corporate Tax

This Interpretation Note provides guidance on the application of the proviso to the definition of “g...

Will trusts still be the way to go? The new sectio...

10 August 2016
Corporate Tax

Authors: Emil Brincker and Louis Botha

South Africa's first transfer pricing case?

16 July 2018
Corporate Tax

Author: Jerome Brink

Reducing the cost of transfer pricing compliance...

18 June 2018
Corporate Tax

Author: Okkie Kellerman

Weekly transfer pricing roundup – 17 July 2017

17 July 2018
Corporate Tax

Author: Marcus

Weekly transfer pricing roundup – 26 June 2017

26 June 2017
Corporate Tax

Author: Marcus

Global transfer pricing risk management

28 September 2016
Corporate Tax

Author: Okkie Kellerman

Treatment of transfer pricing secondary adjustmen...

11 April 2016
Corporate Tax

Author: Grant Thornton South Africa

Paragraph 51A relief deadline of 31 December 2012...

12 December 2012
Corporate Tax

Posted by: SAIT Technical

BPR 133: Transfer of a residence out of a company...

17 January 2013
Corporate Tax

Posted by: SAIT Technical

OECD’s base erosion and profit shifting action pla...

09 February 2016
Corporate Tax

Author: Lisa Brunton

Binding Private Ruling 133 (Tax Alert)

28 January 2013
Corporate Tax

Posted by: SAIT Technical

Non-submission of transfer pricing documentation i...

28 May 2018
Corporate Tax

Authors: Karen Miller & Carryn Alexander

Capital gains tax and the primary residence exemp...

25 April 2013
Corporate Tax

Author: Mansoor Parker

Procedure is everything

04 May 2018
Corporate Tax

Author: Louis Botha

Author: OECD

13 December 2016
Corporate Tax

Author: OECD

Receipt of Foreign Assets and the Subsequent Donat...

04 December 2013
Corporate Tax

Author: BDO

Higher price on carbon needed to effectively tack...

09 December 2015
Corporate Tax

Author: OECD

Disposals by share incentive trusts

04 August 2014
Corporate Tax

Author: Heinrich Louw

Professional tax advice vital in mitigation of pe...

08 December 2014
Corporate Tax

Author: Andrew Lewis

Could capital gains tax be increased?

02 February 2015
Corporate Tax

Author: Ingé Lamprecht

Could capital gains tax be increased?

02 February 2015
Corporate Tax

Author: Ingé Lamprecht

Higher price on carbon needed to effectively tackl...

09 December 2015
Corporate Tax

Author: OECD

Additional taxes are in the pipeline

04 February 2015
Corporate Tax

Author: Wiseman Khuzwayo

Cross-issue of shares

02 March 2015
Corporate Tax

Author: Heinrich Louw

Matthew Lester unpacks wealth taxes in light of th...

04 March 2015
Corporate Tax

Author: Matthew Lester

Tax treaties: OECD releases latest MAP statistics

24 November 2015
Corporate Tax

Author: OECD

Feedback from National Treasury workshop: Cross-is...

05 February 2015
Corporate Tax

Author: Lesedi Seforo

The implementation of BEPS - how it may all come...

20 November 2015
Corporate Tax

Author: Esther Geldenhuys

Capital gains tax deferred

21 April 2015
Corporate Tax

Author: Ben Strauss

New rules for cancellation of contracts

28 July 2015
Corporate Tax

Authors: Denny da Silva and Elandre Brandt

Scope of capital gains tax liability broadened

18 August 2015
Corporate Tax

Authors: Gigi Nyanin and Nicole Paulsen

Market value of shares on valuation date

05 October 2015
Corporate Tax

Author: Heinrich Louw

Determining the CGT base cost of shares in a priva...

02 November 2015
Corporate Tax

Author: PwC South Africa

Widening the scope of Capital Gains Tax liability

17 November 2015
Corporate Tax

Author: Donatella Callaway

A win against SARS: late delivery of SARS’s rule 3...

01 December 2017
Corporate Tax

Author: Mareli Treurnicht

Commercial property: three ways to save tax

13 June 2016
Corporate Tax

Author: Ben Strauss

Exempt dividends treated as income or proceeds fo...

18 September 2017
Corporate Tax

Authors: Craig Miller and Joon Chong

Closing window for tax and exchange control relief

16 October 2017
Corporate Tax

Author: Scott Salusbury

SARS issues binding class ruling regarding unbundl...

21 June 2019
Corporate Tax

Authors: Tsanga Mukumba and Louis Botha

Proposed amendments to clarify income tax treatme...

04 June 2019
Corporate Tax

Authors: Robert Gad, Megan McCormack and others

Tax exemption is not a formality – the Tax Court...

03 June 2019
Corporate Tax

Authors: Louis Botha and Louis Kotze

Timing of tax on gift cards

29 April 2019
Corporate Tax

Author: Ben Strauss

Proposed amendments to clarify income tax treatmen...

19 December 2019
Corporate Tax

Authors: Robert Gad , Megan Mccormack And Jo-Paula Roman

Controlled foreign company comparable tax thresho...

19 December 2019
Corporate Tax

Author: Tsangadzaome Mukumba

A creature of statute: A decision about the Tax C...

19 December 2019
Corporate Tax

Authors: Louis Botha and Louis Kotze

Unintended consequences of the new CFC rules

06 May 2020
Corporate Tax

Author: Judith Becker

New tax change taxes dividends in a collective in...

19 December 2019
Corporate Tax

Author: Magda Snyckers

Carbon Tax Bill: finalisation & voting; Financial...

19 December 2019
Corporate Tax

Author: Parliamentary Monitoring Group

Win for the employer: Judgment on the Employment T...

19 December 2019
Corporate Tax

Authors: Louis Botha and Louis Kotze

Important judgment for taxpayers regarding the va...

19 December 2019
Corporate Tax

Author: Jerome Brink

SA tax penalties on companies

06 May 2020
Corporate Tax

Author: Nico Theron

Disallowance of the utilisation of an assessed los...

19 December 2019
Corporate Tax

Author: Gigi Nyanin

No capital gains tax? Ruling on the disposal of p...

19 December 2019
Corporate Tax

Author: Louis Botha

Tax avoidance – when does it apply?

27 May 2021
Corporate Tax

Author: Peter Dachs

Ruling on customer loyalty programme

19 December 2019
Corporate Tax

Author: Heinrich Louw

No tax deduction for damages paid for deliberate b...

19 December 2019
Corporate Tax

Authors: Ben Strauss and Jerome Brink

Exchange Control: Recent amendments to the Currenc...

19 December 2019
Corporate Tax

Author: Louis Botha

Corporate reorganisations: the dividend stripping...

27 May 2021
Corporate Tax

Authors: Nicolette Smit and Stephan Minne

Crossing borders: The not-so-golden loop structur...

06 May 2020
Corporate Tax

Author: Louis Botha

Accrual of amount on cession of right to dividends

06 May 2020
Corporate Tax

Author: Ben Strauss

A re-prioritising of sorts - between the anti-avo...

19 December 2019
Corporate Tax

Author: Louis Botha

A long-awaited guide on venture capital companies...

19 December 2019
Corporate Tax

Author: Gigi Nyanin

Controlled foreign companies: look before you leap

27 May 2021
Corporate Tax

Authors: Carmen Gers and Simone Krupanandham S

The capital v revenue question in the context of...

19 December 2019
Corporate Tax

Authors: Louis Botha and Louise Kotze

Carbon Tax Bill: Treasury response to submissions

19 December 2019
Corporate Tax

Author: Parliamentary Monitoring Group

Efficient or inept? South Africa’s corporate incom...

19 December 2019
Corporate Tax

Author: Candice Gibson

SARS issues binding class ruling regarding unbund...

06 May 2020
Corporate Tax

Friday, 21 June 2019 Authors: Tsanga Mukumba and Louis Botha (Cliffe Dekker Hofmeyr) Important:...

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