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Groups of companies often wish to restructure or rationalise their operations. This generally involves a transfer of companies and/or assets between various entities.

Below, please find issue 69 of ENSafrica's tax in brief, a snapshot of the latest tax developments in South Africa.

South African businesses play an integral role in socio-economic upliftment and development of communities. Expenditure incurred for this purpose may have tax implications for the business involved.

In a High Court of South Africa judgment, delivered on 23 March 2020 by Judge J. Mabusa, in the case of CSARS v Public Protector and Others, it was ordered that the South African Revenue Service...

In a significant judgment handed down on 5 September 2025 and published by SARS today, the Tax Court upheld an appeal by Taxpayer MPT against additional royalty assessments...

For financial year-end purposes, taxpayers consider the tax provisions as part of the company's financial position and how this will be disclosed in their annual financial statements

The Constitutional Court’s judgment in Absa Bank Ltd and Another v C:SARS is one of the most important tax judgments delivered in South Africa in recent years.

In difficult economic times, debt capitalisation may afford companies some room to improve their financial position.

According to recent reports, startups in South Africa raised over $832m in 2021.

These are among the questions facing many South African taxpayers – and for a growing number, the answer lies in offshore trusts.

The Minister of Finance has proposed two amendments to the regulations which govern transfer pricing transactions between related entities as well as to the documentation requirements as outlined in ...

In recent years, SARS' has become increasingly litigious, resulting in disputes often ending up in the Tax Court or the High Court. Such a dispute will generally arise when a taxpayer...

Tax litigators will now have to consider, inter alia, the impact of certain provisions under the Tax Administration Act No. 28 of 2011 as amended by the Tax Administration Laws Amendment Act No. 21 of 2012 on the doctrine of legal professional privilege and a recent judgment reflecting the view of a court with regards to the adherence to the rules of the Tax Court by the South African Revenue Service.

In terms of the current Tax Court rules published under the Income Tax Act No. 58 of 1962, there was little that a taxpayer could do.

It is always difficult to predict certain issues which may arise when the legislation is being drafted and often practical issues only arise subsequent to the promulgation of tax Acts.

With the 2025 Budget Speech fast approaching, speculation is mounting over whether South Africa will introduce a wealth tax as part of broader fiscal reforms. With growing concerns about revenue shortfalls.

The Appellant (KRA) initiated an audit on the Respondent (Sendy Limited), a digital platform connecting third-party transporters to customers. KRA raised a VAT assessment of Kshs 82,248,150.74 on Sendy's gross receipts...