July 2026

Tax Court Sends Anti-Avoidance Warning to Taxpayers with Complex Artificial Tax Structures Richan SchwellnusTeam Lead: Tax Controversy & International Tax FEATURED IN: In a recent Tax Court judgment involving seven interconnected corporate taxpayers, the Court upheld the South African Revenue Service’s (SARS) position that a carefully structured corporate acquisition amounted to a so-called “impermissible avoidance …

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SARS Cancels Trust Penalties – But Only for Now Sidney FletcherSenior Manager: Tax Compliance FEATURED IN: The South African Revenue Service (SARS) has provided welcome temporary relief to thousands of trustees across the country by withdrawing certain administrative penalties and final demand notices that were recently issued in respect of outstanding Trust Income Tax Returns …

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Overseas but Not Off the Hook: SARS Filing Rules Explained John-Paul FraserPartner and Head of Strategic Engagement & Compliance Vivian CoxExpatriate Tax Consultant FEATURED IN: With the 2026 tax filing season underway, South African expatriates should take note that they may still be required to submit annual tax returns to the South African Revenue Service …

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SARS Finally Publish a Draft Guide to Taxation of Crypto Assets, for Public Comment Jashwin BaijooPartner and Head of Strategic Engagement & Compliance FEATURED IN: On 1 July 2026, the South African Revenue Service (SARS) published its “Draft Guide to the Taxation of Crypto Assets”, providing important insight into how SARS views crypto assets with …

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High Court Upholds SARS’ Challenge to R10 Million Insurance Deduction Richan SchwellnusTeam Lead: Tax Controversy & International Tax Charlotte McLarenTax Associate: Tax Controversy & Dispute Resolution FEATURED IN: On 26 June 2026, the Western Cape High Court, in Commissioner for the South African Revenue Service v Meiring Citrus (Pty) Ltd, upheld SARS’s appeal and held …

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Why Expatriates’ First Tax Residence Certificate May Not Protect Their Earliest Period of Foreign Employment André DanielsHead of Tax Controversy & Dispute Resolution FEATURED IN: Many South Africans working abroad who rely on a Tax Residence Certificate (“TRC”) to support a Double Tax Agreement (“DTA”) non-residency position are discovering that the certificate does notalways cover …

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