South Africa: Tax Authorities

ENS's Tax in Brief Issue 170 delivers a comprehensive snapshot of South Africa's evolving tax landscape, covering a landmark Constitutional Court ruling on VAT zero-rating for recycled gold, new draft regulations on domestic reverse charge mechanisms for valuable metals, and critical updates to PAYE reconciliation requirements. The bulletin also examines SARS's implementation of Global Minimum Tax returns, Filing Season 2026 enhancements, and significant customs and excise amendments including China's Zero-

South Africa's tax landscape is evolving with new border control requirements, refined R&D incentives, and recent SARS rulings on mining rehabilitation and equity structures. What do these developments mean for businesses operating across borders and claiming tax relief?

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.

South Africa's Global Minimum Tax (GMT) regime applies to large multi-national entity (MNE) groups with global consolidated revenues exceeding €750 million (in at least two of the four preceding fiscal years).

South Africa's 2026 Budget marks a significant step forward in the regulation of crypto assets, particularly in relation to cross-border capital flows.

On 6 February 2026, the Africa Tax Administration Forum ("ATAF") published a Technical Note summarising changes to the Global Minimum Tax ("GMT"), referred to as a "Side-by-Side Package".

South Africans can start with one basic certainty: nothing in the South African Income Tax or Reserve Bank regulations prohibits South African nationals...

In order to encourage tax compliance and to deter unwanted behavior of non-tax compliances including tax evasions, the South African Revenue Service (SARS) which administers tax Acts is empowered to impose sanctions...

SARS has officially announced the dates for the 2025 tax filing season.