ARTICLE · 18 MAY 2026

Tax On Brief

ENS

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This comprehensive legal update covers recent developments across South African law, from pharmaceutical naming regulations and copyright platform liability to VAT amendments affecting insurance and digital services. The collection explores emerging challenges in intellectual property protection, cryptocurrency regulation, and data brokerage compliance.

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Below, please find issue 167 of ENS’ tax in brief, a snapshot of the latest tax developments in South Africa.

case law

Constitutional Court | Absa Bank Ltd and Another v Commissioner for the South African Revenue Service (CCT 72/24) [2026] ZACC 15
- Find the ENS tax team’s newsflash on this important judgment regarding the General Anti-Avoidance Rules ("GAAR") here.
- Find a copy of the judgment here.
Tax Court | Taxpayer Bank Limited v Commissioner for the South African Revenue Service (VAT 32666) [2026] ZATC JHB
- The taxpayer, a bank, introduced a “cashback scheme” in terms of which clients who met certain qualifying criteria had their monthly banking fees credited to their accounts, and the taxpayer claimed an input tax adjustment in respect thereof which was denied by SARS.

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