South Africa: Income Tax

ENS presents issue 169 of its tax brief, examining recent South African tax court rulings on locomotive supply agreements, fuel distributor deductions, and search warrant validity. The publication analyzes multiple High Court decisions involving customs disputes, VAT payments in liquidation proceedings, and manufacturing rebate eligibility, while also covering SARS's latest guidance on beneficial ownership declarations and voluntary disclosure programmes.

This issue of ENS' tax in brief provides a comprehensive snapshot of recent tax developments in South Africa, covering significant Supreme Court and High Court judgments on taxpayer representation and customs seizures, legislative amendments to customs rules and fuel levies, SARS publications on compliance requirements, and updates on exchange control regulations including crypto asset treatment.

The African Tax Administration Forum and OECD have concluded transfer pricing workshops for Francophone tax officials, while multiple African nations implement significant tax reforms including VAT changes, e-invoicing requirements, and new compliance measures. From Kenya's reduced petroleum VAT rates to Liberia's comprehensive tax amendments and Uganda's proposed alternative minimum tax, these developments reflect a continent-wide effort to modernize tax administration and enhance revenue collection.

On 25 February 2026, Minister of Finance Enoch Godongwana delivered the anticipated National Budget against a backdrop of slow economic growth, persistently high unemployment, rising living costs...

It is becoming increasingly unlikely that SARS will meet the collection targets required to achieve the additional R35 billion reflected in National Treasury's monthly publications.

Individual tax brackets had not been adjusted for several years, and although a VAT increase was previously proposed, it was ultimately withdrawn.

While some high-profile share swaps in the retail and lifestyle sector have left a bitter aftertaste, it is important to remember that not all corporate restructures are cautionary tales.

When a company faces liquidation, winding-up or deregistration the instinct might be to brace for tax consequences, but section 47 of the Income Tax Act 58 of 1962...

BENIN: Application of 1% stamp duty on specified cash payments clarified...