
Dividend-stripping case sharpens the boundaries of legitimate tax planning
The Tax Court has affirmed the choice principle but raised fresh questions about where legitimate tax-efficient structuring ends and impermissible avoidance begins.

The Tax Court has affirmed the choice principle but raised fresh questions about where legitimate tax-efficient structuring ends and impermissible avoidance begins.

Practitioners warn that applying section 7(8) to cross-border trust distributions could create onerous and potentially perpetual tax and compliance consequences.

Trustees face growing pressure to file outstanding returns or formally deregister dormant trusts before penalties escalate.

Companies are under growing pressure to prove that the figures in returns, financial statements, and supporting documents all tell the same story.

The new APA process aims to reduce disputes and double taxation, but practitioners say the entry bar is so high that few groups will qualify.

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

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.

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.

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.