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Few international and multinational companies in South Africa have escaped a section 31 transfer pricing examination by the South African Revenue Service ("SARS").

The stated policy of the South African Revenue Service (SARS) not to make value-added tax (VAT) apportionment rulings effective retrospectively...

The new ‘Two-Pot' retirement system came into effect on 1 September 2024 changing South Africa's retirement savings structure to improve financial security and encourage long-term retirement savings.

The Minister of Finance, Enoch Godongwana, will announce new tax proposals in the 2023 Budget which will be delivered on 22 February 2023.

South Africa's Finance Minister will deliver his budget speech to Parliament on 21 February 2024.

The supply of most goods or services in South Africa is subject to value-added tax ("VAT") at 15%. Where cross-border services are involved, challenges can arise to establish whether the non-resident...

On 25 February 2026, Minister of Finance Enoch Godongwana delivered the anticipated National Budget against a backdrop of slow economic growth, persistently high unemployment, rising living costs...

Individual tax brackets have not been adjusted since 2023/2024 tax year. The 2026/27 budget speech proposes an inflation adjustment for the tax tables and medical aid tax credits which should be welcomed...

The provisions in the Income Tax Act No. 58 of 1962 pertaining to the taxation of Real Estate Investment Trusts ("REITs") are contained in section 25BB and were introduced into the Act with effect from 1 April 2013.

The Organization for Economic Cooperation and Development has recently issued a 15 point action plan on base erosion and profit shifting.

The National Fiscal Stabilisation Levy Act, 2013 (Act 862) which was gazetted on 15 July 2013, requires certain entities to pay 5% of their profit before tax as a NFSL levy on a quarterly basis.

Dividends, other than certain foreign dividends, received by or accrued to or in favour of any person, do not constitute ‘income’ as defined in section 1 of the Income Tax Act, Act 58 of 1962 ("the Act"), being exempt from normal tax under section 10(1)(k)(i) of the Act.

Where the HTVI approach applies, tax administrators are entitled to consider ex post outcomes as presumptive evidence in evaluating the appropriateness of ex ante pricing arrangements.

The High Court, Gauteng Local Division, considered in a recent case whether an agreement in terms of which a legal practitioner charged contingency fees to a client under the Contingency Fees Act, No 66 of 1997, is valid.

Section 9D of the Income Tax Act, 1962 (the "Act") is aimed at South African residents who directly or indirectly hold more than 50% of the total participation (broadly speaking shares) or voting rights in a foreign company.

The South African Revenue Service (SARS) is in the process of amending the rule to facilitate customs related submission resulting from transfer pricing adjustments ("TPA").

In our recent article, we discussed that South Africa has until 30 February 2023 to meet a tight deadline to amend its Financial Intelligence Centre Act, 2001 ("FICA") or face the consequences...