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ENS presents issue 171 of its tax brief, covering recent South African tax developments including significant Supreme Court and Tax Court judgments on import duties, dividend stripping arrangements, and insurance contract deductions. The brief also details new SARS filing requirements, updated guides for the 2026 filing season, and important changes to customs procedures and VAT treatment of ambulance services.

A recent decision of the Cape Town Tax Court highlights uncertainty surrounding the application of the double tax agreement between South Africa and Luxembourg in relation to South Africa’s so-called exit charge.