In South Africa, interest is deductible under the Income Tax Act, whether or not the interest is capital in nature, provided the interest is incurred “in the production of income” […]
Commission earnings and taxation
Commission earners who earn more than 50% of their total remuneration as commission income are not limited in the type of business expenses they can claim, as long as these […]
Leasehold improvement allowance and Section 11(h) of the Income Tax Act
Source: Private Binding Ruling BPR 401 of 14 December 2023 This ruling determines the tax consequences for a lessor in respect of improvements effected by a lessee. In this ruling […]
Donations tax implications on the issue of shares at nominal value to enhance B-BBEE credentials
ACT: Income Tax Act 58 and a SARS General Binding Ruling, Number 400. This ruling by SARS determines whether donations tax will be payable on the amendment of a company’s […]
Taxpayers and retention of records as per the Tax Administration and Companies Acts
Relevant Act: Tax Administration ActGovernment Notice 787 of 01 October 2012; Gazette 35733Electronic Communications and Transactions ActCompanies Act A person must keep records, books of account, or documents. The retention […]
Tax Consequences of the Termination of an En Commandite Partnership
Binding Private Ruling 391 ACT: INCOME TAX ACT 58 OF 1962SECTION: PARAGRAPH 1 – DEFINITION OF “ASSET”, “DISPOSAL” and “VALUE SHIFTING ARRANGEMENT”, and PARAGRAPH 11 OF THE EIGHTH SCHEDULE TO […]
Disposal of shares subsequent to a property development arrangement.
Disposal of shares subsequent to a property development arrangement, BINDING PRIVATE RULING 398, November 2023 This ruling describes the tax consequences of the disposal of ordinary shares in a property […]
Section 18A – Audit Certificates, Part 2
ACT: Income Tax Act 58 OF 1962, Section 18A(2B) AND (2C) This is part 2 of 2 in this series of articles. Please read part 1 before reading this second […]
The Two-Pot Retirement System
Amendments to the Pension Funds Amendment Bill and the Revenue Laws Amendment Bill The two-pot retirement system is a reform that will allow retirement fund members to make partial withdrawals […]
Section 18A – Audit Certificates, Part 1
ACT: Income Tax Act 58 OF 1962, Section 18A(2B) AND (2C) This article summarises key elements of SARS Guidance Note 112 on the interpretation and application of section 18A(2B) and […]










