South Africa: Income Tax

South Africa's transition from JIBAR to ZARONIA introduces Credit Adjustment Spreads (CAS) to preserve loan economics, but what happens when parties negotiate their own spread instead of using the official rate? The draft finance bill empowers SARB to set mandatory CAS values, yet leaves critical tax questions unanswered for those who deviate from the prescribed methodology.

Issue 164 of ENS' tax in brief, a snapshot of the latest tax developments in South Africa.

The transition from the Johannesburg Interbank Average Rate (JIBAR) to the South African Rand Overnight Index Average (ZARONIA)...

The South African regulatory environment governing cross-border financial transactions has recently undergone a dramatic and unexpected overhaul.

In South Africa, the Income Tax Act No. 58 of 1962 ("the Act") provides tax exemptions to registered and qualifying Public Benefit Organisations ("PBOs").

The recent media statement from the National Treasury announcing the retraction of the proposal regarding the definition of a "hybrid equity instrument" from the 2025 draft Taxation Laws Amendment Bill is a significant development for South African businesses.

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

The South African tax system, just like many other tax systems around the globe, substantially operates on selfreporting or self-assessments.

On 12 May 2025, the Supreme Court of Appeal ("SCA") delivered a notable judgment clarifying the treatment of tax liabilities and Value Added Tax ("VAT") refunds in the context of business rescue proceedings.