On Friday, 14 October 2022, the South African Revenue Service (SARS) published a Draft Interpretation Note: Definition of “Associated Enterprises” (the Note) for public comment. This Note provides guidance on […]
Income Tax
Section 11D of the Income Tax Act – Research & Development (R&D) tax incentive’s proposed amendments
The Government is proposing to extend the Research & Development (R&D) tax incentive beyond 31 December 2023 – likely for a period of 10 years following a consultation process with […]
Declaration of a crypto asset as a financial product under the Financial Advisory and Intermediary Services Act
On 19 October 2022, the Financial Sector Conduct Authority (FSCA) published General Notice 1350 of 2022 in Government Gazette 47334 (Notice), wherein “crypto assets” were declared ‘financial products’ under section […]
NPOs, corrupt activities and the Financial Action Task Force (FATF)
Source: BEST PRACTICES – COMBATING THE ABUSE OF NON-PROFIT ORGANISATIONS (RECOMMENDATION 8) – 2015 by the FATF South Africa has an established and functioning system, including the establishment of a […]
Public Schools and Income Tax
Although public schools are exempt from Income Tax, in terms of section 10(1)(cA)(i) of the Act, they are still liable for the submission of annual income tax returns. Public schools […]
Contributed Tax Capital and Preference Shares
The concept of contributed tax capital (CTC) was introduced into the Income Tax Act, No 58 of 1962 (Act) with effect from 1 January 2011. The relevance of the concept […]
Contributed Tax Capital and Preference Shares
The concept of contributed tax capital (CTC) was introduced into the Income Tax Act, No 58 of 1962 (Act) with effect from 1 January 2011. The relevance of the concept […]
Tax Avoidance and Income Tax Act
Section 80A(c)(ii) of the Income Tax Act 58 of 1962, as amended, introduced a new concept to the South African income tax environment: misuse or abuse of the provisions of […]
Withholding Tax on Royalties
Source: sars.gov.za Documents referred to in this article: WTR01 – return formWithholding Tax on Royalties Declaration (WTRD)Withholding-Tax-on-Royalties-Summary-of-DTA-Rates-AfricaWithholding-Tax-on-Royalties-Summary-of-DTA-Rates-Rest-of-the-World This article summarizes the detail of the Withholding Tax on Royalties. The WTR […]
Tax Implications for Resident Beneficiaries of a Foreign Pension Trust
SOURCE: SARS BINDING CLASS RULING: BCR 080 DATED 12 August 2022 ACT: INCOME TAX ACT 58 OF 1962 (the Act) ESTATE DUTY ACT 45 OF 1955 (Estate Duty Act), SECTION […]










