
ConCourt ruling expands GAAR reach and raises investor risk
A wider interpretation of ‘party’ under GAAR means even commercially sound participants may face SARS’s scrutiny in multi-entity transactions.

A wider interpretation of ‘party’ under GAAR means even commercially sound participants may face SARS’s scrutiny in multi-entity transactions.

The Court finds that cashback credits reduced the original fee, rather than constituting payment for a separate supply by customers.

As third-party submissions open, SARS urges employers to file early and accurately or risk triggering errors, delays and taxpayer verifications.

The bona fide inadvertent error defence is limited to substantial understatements, but there is relief for taxpayers seeking to challenge estimated assessments.

Rising the VAT threshold to R2.3m may prompt some businesses to deregister, but the process can trigger an immediate output tax liability on assets.

Tax experts say the constitutional problem identified by the High Court could affect several other laws that give the finance minister similar powers.

Allan Gray explores how embedded gains, tax rates, investment horizon, and executor’s fees affect the decision to switch offshore investments into endowments.

SARS cannot fundamentally alter the factual basis or remedy of an assessment issued under the general anti-avoidance rule provisions through a Rule 31 statement.

The new reporting regime, effective from 1 March, increases the information available to SARS through third-party reporting and international data exchange.

Using AI and third-party data, SARS identified some 100 000 high-income earners who were not registered for tax.

Just a year after the Constitutional Court barred post-agreement interest remission in voluntary disclosure cases, Treasury proposes legislation to allow it.

The government finally cuts payers of personal income tax some slack – and increases the medical scheme tax credits.

Treasury also proposes new thresholds at which fund members and living annuitants can commute to a cash lump sum.

The tax regime for small and micro-businesses will also be adjusted for inflation.

Advocates say including certain chicken products in the zero-rated food basket will directly benefit poorer households that rely on bone-in cuts and offal.

With no inflation adjustment in 2025, PIT collections rose sharply, increasing the burden on individuals without changes to the headline rates.

The Office of the Tax Ombud is seeing the same delays, verification snags, and procedural irregularities highlighted by a tax practitioner.