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Dividends paid by one South African company to another have been exempt from both normal tax and dividends tax since April 2012 when dividends tax came into effect.

"If internationally there is evidence that reducing tax rates may impact positively on growth and unemployment, and then this option should certainly not be ignored."

If SARS is not satisfied with the estimate prepared by the taxpayer, the first provisional tax payment will be queried.

The long-awaited double tax agreements entered into by Kenya with South Africa and Mauritius respectively did not come into force on 1 January 2015 as expected.

SARS recently published a first bash of legislation to be included in the Revenue Laws Amendment Bill to be promulgated later this year. In this context the following amendments are relevant:

It was announced in the 2012 budget speech of the Minister of Finance, Pravin Gordhan, on 22 February 2012 that the taxation of dividends will be increased from the current 10% secondary tax on companies ("STC") to a 15% dividend withholding tax with effect from 1 April 2012.

One of the welcome announcements by the Minister of Finance in his budget speech delivered in February this year, pertained to a potential further relaxation...

On 6 October 2022, as part of the ongoing work of the OECD/G20 Inclusive Framework ("IF") on Base Erosion and Profit Shifting ("BEPS") to implement the Two-Pillar solution to address...

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 ("SARS") assessed the taxpayer for employees' tax for the period 1 March 2003 to 29 February 2008 in terms of the provisions of the Fourth Schedule to the Income Tax Act No. 58 of 1962 ("Act").

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

Practically, relevance can only be determined at the time that the information is requested and such information must remain within the scope of the audit.

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

Is there any legislation that governs the nature, amount or manner or frequency of payments of royalties or other fees or costs (including interest on late payments) in an international licensing relationship, ...

Special Economic Zones in South Africa face a critical VAT discrepancy that can cost operators up to 15% of government grant funding. The inconsistent treatment between designated entities under Section 8(5) and other vendors under Section 8(5A) creates a two-tier system that directly impacts infrastructure delivery and investment readiness across the SEZ programme.

On 28 March 2011 SARS issued a draft interpretation note (DIN) regarding the application of section 9C of the Act, the so called "safe haven" provision on shares.

On 19 July 2017, the South African National Treasury released the 2017 Draft Taxation Laws Amendment Bill ("draft TLAB") for public comment.