News

Marriage May No Longer Be Enough: Treasury Draws a Residency Line Through the Spousal Donations Tax Exemption Delano AbdollLegal Manager: Cross-Border Taxation Mbalenhle MahlabaTeam Lead: Expatriate Tax FEATURED IN: The 2026 Draft Taxation Laws Amendment Bill makes the recipient spouse’s tax residence the decisive question — and proposes to do so from 25 February 2026.

National Treasury Publishes 2026 Draft Tax Bills for Public Comment FEATURED IN: On 30 July 2026, National Treasury and South African Revenue Service (SARS) published the 2026 Draft Taxation Laws Amendment Bill (TLAB) and the 2026 Draft Tax Administration Laws Amendment Bill (TALAB) for public comment. The draft bills contain the tax proposals made in

Always Ask SARS for Reasons: The Supreme Court of Appeal’s Most Important Lesson for Taxpayers André DanielsHead of Tax Controversy & Dispute Resolution FEATURED IN: The recent Supreme Court of Appeal (SCA) judgment in QI Logistics (Pty) Ltd v Commissioner for theSouth African Revenue Service, reinforces one of the most important procedural rights available to taxpayers: when SARS makes an adverse decision, the taxpayer must ask for reasons. Too often, after months of an audit, verification or investigation, SARS issues

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

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

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

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

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

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

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