Tax Break: South African tax for professionals
Today: #167 in Business, South Africa on our combined chart.
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Latest episodes
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Dividend stripping and the GAAR: CGT and USPs
October 8, 2026 · 15 minDoes the July 2026 tax court judgment on dividend stripping and the general anti-avoidance rule (GAAR) mean these transactions can no longer be done? This episode answers a listener's question about that case and reads it against section…
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Interest deduction limitations: section 23M of the Income Tax Act
September 17, 2026 · 13 minWhen does section 23M of the Income Tax Act limit the interest a company can deduct on debt owed to a creditor in a controlling relationship, and why is it not just a cross-border rule? This episode of Tax Break highlights three pointers…
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Fixing bona fide errors on tax returns: USP risks
September 10, 2026 · 15 minUnderstatement penalties (USP) and bona fide inadvertent errors after the amendment to section 222 of the Tax Administration Act (TAA): if you correct an error on a return that has already been assessed, has the amendment created a new…
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Reportable arrangements: section 35 of the Tax Administration Act
September 3, 2026 · 15 minReportable arrangements (RAs) under section 35 of the Tax Administration Act are often overlooked by advisors, and frequently only surface when an accountant reaches the "reportable arrangement" question on the tax return. This episode of…
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Are self-insurance premiums tax deductible? The Meiring Citrus judgment
August 27, 2026 · 19 minAre self-insurance premiums deductible? In this episode of Tax Break, I discuss the deductibility aspect of the Western Cape High Court judgment in CSARS v Meiring Citrus (Pty) Ltd. I cover: The two grounds that SARS abandonedThe court’s…
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Section 99 prescription: When can SARS reopen a tax assessment after three years? CSARS v Meiring Citrus
August 20, 2026 · 26 minWhen does prescription protect taxpayers from SARS issuing additional assessments? Section 99 of the Tax Administration Act generally bars SARS from issuing an additional assessment more than three years after the original assessment…
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2026 draft TALAB: PAYE for foreign employers with SA permanent establishments, provisional tax penalties and VDP changes
August 13, 2026 · 12 minThe National Treasury published the 2026 draft Tax Administration Laws Amendment Bill (draft TALAB) for public comment on 30 July 2026. In this episode, I discuss three proposed amendments with clear practical impact for South African…
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2026 Draft Tax Bills: CFCs, dividend stripping, interest deductions, VAT on leasehold improvements
August 6, 2026 · 19 minSouth Africa’s National Treasury published the 2026 draft tax law amendments for public comment on 30 July 2026. Although proposals are technical, tax practitioners and CFOs need to assess whether their businesses or clients are…
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CSARS v Meiring Citrus: substance over form, simulation and the deductibility of insurance premiums
July 30, 2026 · 17 minDoes the label on a contract determine its South African tax consequences? If you call an agreement a loan, are the payments deductible interest? If you call it a lease, are the outflows deductible rent? In CSARS v Meiring Citrus the…
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Are your zero-rated supplies really zero-rated?
July 23, 2026 · 14 minZero-ratings are complex and often underestimated by taxpayers and their advisors. The exposure may be significant if you get it wrong, especially on recurring transactions. Interpretation Note 31 is an essential part of applying a…
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Taxation of crypto assets
July 16, 2026 · 16 minSARS issued a draft guide on the taxation of crypto assets. In this episode, I discuss a few aspects of this draft guide that I believe offer valuable insights into SARS’ position on these assets. You can contact me at …
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Section 42: What is it not? (Part 2)
July 9, 2026 · 17 minSection 42 of the Income Tax Act provides relief for asset-for-share transactions. In this episode, I discuss some anti-avoidance rules to consider when dealing with asset-for-share transactions. You can contact me at p…