South Africa: Tax

This issue of ENS' tax in brief provides a comprehensive snapshot of recent South African tax developments, including significant High Court judgments on SARS appeals and enforcement orders, new SARS publications on documentary proof requirements and the Advance Pricing Agreement programme, and multiple customs and excise tariff amendments affecting various imported goods. The brief also covers important international developments from the OECD regarding the Global Minimum Tax implementation and corporate t

This comprehensive update covers significant tax and regulatory developments across 30 African jurisdictions during mid-2026, including Angola's new oil block incentives and unified Personal Income Tax Code, Botswana's major tax rate increases and transfer pricing regulations, Kenya's Finance Act 2026 with mortgage interest relief expansion, Nigeria's implementation of the unified Taxpayer Identification system and presumptive tax regime, and Rwanda's new transfer pricing rules framework. The bulletin exami

The Western Cape High Court's recent ruling in C:SARS v Meiring Citrus overturned a Tax Court decision and disallowed a ZAR9.6 million income tax deduction claimed by a citrus farmer for what was marketed as an insurance premium. The judgment raises critical questions about the distinction between genuine insurance and investment arrangements, the burden of proof in prescription cases, and the application of accounting standards to tax deductions. Taxpayers with similar structured self-insurance products sh