Accordingly, it is possible that in drafting the CbC legislation, SARS and National Treasury will make reference to the Australian legislation to implement CbC reporting which was enacted in December 2015.

Under tax incentives, the Minister proposed to introduce a local content allowance for income tax, relating to the use of selected local raw materials, at the rate of 2%.

In its first and much anticipated judgement in relation to the interpretation of section 8A of the Income Tax Act, and to Deferred Delivery Share Schemes, a full bench of the Supreme Court of Appeal unanimously upheld the taxpayers’ contentions.

An impending amendment to the revenue laws could cause a purchaser of immovable property to pay up to 10% of the purchase price by way of tax on behalf of a seller, plus penalties.

The Commissioner for the South African Revenue Service recently published a Draft Interpretation Note on the allowance of future expenditure on contracts in terms of section 24C of the Income Tax Act 58 of 1962.

In terms of the ‘pay now and argue later principle’ taxpayers are obliged to pay the South African Revenue Service any taxes due; albeit any pending court decisions or objections against any assessments.

In his Medium-Term Budget Policy Statement, in October 2019, Finance Minister Mboweni warned that new tax measures may be announced.

In December last year, the Organisation for Economic Co-operation and Development (OECD) released the Pillar Two Model Rules as approved by the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS).

Due to the importance of prescription for taxpayers in obtaining finality as to their tax affairs, it is crucial for taxpayers to be aware of the prescription status of assessments and their rights in this context.

Employment Tax Incentive ("ETI") programme was introduced in January 2014 to promote employment, particularly of young workers.

The South African Revenue Service ("SARS") increased their audit activity and focus on the collection of tax.

It is becoming increasingly unlikely that SARS will meet the collection targets required to achieve the additional R35 billion reflected in National Treasury's monthly publications.

In February this year SARS published a Draft Interpretation Note on the determination of taxable income of certain persons from international transactions covering intra-group loans.

In the 2012 Taxation Laws Amendment Bill, the long-awaited proposed amendments to sections 8E and 8EA of the Income Tax Act, No 58 of 1962, were published.

SARS has been enforcing penalties on dormant companies where companies have failed to submit tax returns and the request for such returns to be lodged has been ignored.

A number of tax rate increases were announced in the 2017 Budget Review on 22 February 2017. These may impact directly on investment yields and re-investment base of investors.

The South African tax system, just like many other tax systems around the globe, substantially operates on selfreporting or self-assessments.

Many employee share incentive schemes involve the use of trusts to house the shares until such time as they vest in the employees.

In terms of the "pay now, argue later" principle, the South African Revenue Service (SARS) is entitled to collect amounts owing by a taxpayer in terms of an assessment.

The provisions of section 8F of the Income Tax Act, 58 of 1962 (the "Act") regulate "hybrid debt instruments".