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Interest is only deductible if incurred in the production of income and for purposes of carrying on a trade. This requires that the loan in respect of which the interest is paid and the trade/income...

The South African Revenue Service has launched a modernised Diesel Refund System on eFiling, fundamentally changing how businesses register for and manage diesel refund claims. This digital transformation introduces a standalone platform that replaces the VAT-linked model, requiring all existing users to reregister and establish electronic supplier relationships. The transition will occur in phases, with standalone claims functionality expected in 2027 while the current system continues operating in paralle

The filing obligation detailed in the draft notice appears to apply retrospectively for years commencing on or after 1 January 2016.

Are you or your business in a dispute with SARS? Are the right people helping you with your company's dispute? Do you know your rights as a taxpayer?

On Friday 10 March 2023, the Minister of Finance approved new dispute resolution rules under section 103 of the Tax Administration Act, 2011...

In the world of business smart tax planning and compliance are crucial for achieving financial efficiency and minimising risks. Whether you're setting up new operations or considering corporate...

Below, please find issue 55 of ENSafrica's tax in brief, a snapshot of the latest tax developments in South Africa.

International tax law principles deal with the allocation to various jurisdictions of taxing rights in respect of the business profits of a multi-national company.

The South African Revenue Service (SARS) has been given significant powers to perform tax audits on returns submitted by taxpayers.

A particular point of interest in the discussion document is the fact that SARS distinguishes between, what it calls, ‘embedded’ and ‘free-standing’ contingent liabilities.

It is clear that harm would be caused to SARS if a taxpayer realised a capital loss and that capital loss is set off against a capital gain in such year of assessment.

The obligation to make payment by a taxpayer of an assessment is not suspended merely because that taxpayer intends on disputing such assessment

Warranties and indemnities are mechanisms to ensure trust between contracting parties. It is the proof in the proverbial pudding and aims to provide that a party to a contract does what they say they will.

The process to be followed by taxpayers when disputing assessments issued by the South African Revenue Service ("SARS") is set out in the Tax Administration Act, 2011 (the "TAA") read with the rules promulgated under section 103 of the TAA.

On 22 October 2025, the South African Reserve Bank Financial Surveillance Department (SARB) issued Exchange Control Circular No 15/2025 (Excon Circular 15/2025) detailing amendments to section B.3...

With effect from 1 April 2015, the business of a hedge fund has been declared to be a collective investment scheme ("CIS") in terms of section 63 of the Collective Investment Schemes Control Act 45 of 2000 ("CISCA").

Section 191 of the TAA now provides that all tax debts that are due must be set-off against refunds, including the interest thereon, due by the South African Revenue Service to that taxpayer.