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ARTICLE · 05 AUGUST 2026

Cross-border Structuring Between Botswana And South Africa

Cross-border tax compliance between Botswana and South Africa is undergoing significant transformation as SARS deploys AI-driven enforcement tools, Botswana proposes a shift to residence-based taxation, and global minimum...

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Cross-border tax is becoming more complex for businesses operating between Botswana and South Africa. Increased enforcement by SARS, proposed tax reforms in Botswana and ongoing international tax developments are changing how cross-border structures are assessed and managed.

This article examines the latest developments and the implications for businesses with operations, investments or financing arrangements spanning both jurisdictions.

SARS enters the digital era of tax enforcement

SARS is investing heavily in technology to identify tax risk more quickly and accurately. During the 2024/25 financial year, it completed approximately 1.7 million verification cases, raising ZAR95 billion, while 3,757 specialised audits resulted in a further ZAR46 billion in assessments. Appeals involving amounts exceeding ZAR1 million also increased by 12%, reflecting a growing focus on larger and more complex matters.

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The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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