ARTICLE · 11 JUNE 2025

ENS Tax In Brief - Issue 146

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Below, please find issue 146 of ENS' tax in brief, a snapshot of the latest tax developments in South Africa.

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Below, please find issue 146 of ENS' tax in brief, a snapshot of the latest tax developments in South Africa.

case law

IT 35476 [2025] ZATC JHB (25 February 2025)
- The taxpayer appealed additional assessments issued by the Commissioner for the South African Revenue Service ("Commissioner" or "SARS") which treated a large loan account (and interest thereon), owing to him by one of his wholly owned companies, as undeclared income. The taxpayer argued the amounts were capital, not income, and presented reconstructed financial statements to support this. SARS contended that the taxpayer gave inconsistent explanations and failed to provide direct evidence for the source of funds.

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