News

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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The Future of Tax Disputes: Beyond Litigation André DanielsHead of Tax Controversy & Dispute Resolution FEATURED IN: South Africa’s tax dispute landscape is evolving, and recent court rulings suggest that the future of tax dispute resolution is unlikely to be defined by litigation alone. Procedural discipline, strategic engagement and commercial considerations are playing an important …

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SARS Hits Former Tax Residents with Surprise Tax Bills Tshepo ThebyaneSenior Tax Consultant Rendani MakatuSenior Tax Consultant FEATURED IN: South African expatriates who have previously ceased their South African tax residency are often caught off guard by unexpected additional assessments raised by the South African Revenue Service (SARS). This is becoming increasingly common, as many …

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R221 Million Case Shows That Sars Wins in the End — And Why Frivolous Litigation Can Backfire André DanielsHead of Tax Controversy & Dispute Resolution FEATURED IN: Taxpayers embroiled in disputes with the South African Revenue Service (SARS) often believe that if they can eventually settle the outstanding tax debt, the matter will come to …

R221 Million Case Shows  That Sars Wins in the End  — And WhyFrivolous Litigation  Can Backfire Read More »

Caught After Moving R182 Million in Bitcoin Offshore Without Regulatory Approval: High Court Confirms Crypto Falls Within Exchange Control Regulations John-Paul FraserTeam Lead: Cross-Border Taxation and Exchange Control Nkosikhona MajoziTax Attorney FEATURED IN: In a significant judgment for South Africa’s cryptocurrency market, the Johannesburg High Court on 1 June 2026,  ruled that Bitcoin constitutes “money” …

Caught After Moving R182  Million in Bitcoin Offshore  WithoutRegulatory Approval:  High Court Confirms Crypto  Falls Within ExchangeControl  Regulations Read More »