Tax Break: South African tax for professionals

The 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 taxpayers and their advisors, two of which are favourable to taxpayers.
The topics covered:
·       Employees' tax (PAYE): a proposal to narrow the withholding obligations of foreign employers with permanent establishments (PEs) in South Africa
·       Provisional tax: aligning underestimation penalties under paragraph 20 of the Fourth Schedule with actual payments made
·       Voluntary disclosure programme (VDP): broadening the relief available under the Tax Administration Act
Contact me at pieter@pvdz.co.za for feedback or tax advice. More resources at https://tax.pvdz.co.za.

South 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 affected.

In this episode I analyse four key proposals: the interaction between the controlled foreign company (CFC) rules and the domestic treasury management company (DTMC) regime for translating CFC income, the clarification of the dividend stripping anti-avoidance rules, the withdrawal of the alignment between the interest deduction limitations in sections 23M and 23N of the Income Tax Act, and the proposed VAT changes for leasehold improvements.

Contact me at pieter@pvdz.co.za for feedback or tax advice. More South African tax resources: https://tax.pvdz.co.za
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Does 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 Western Cape High Court considered whether premiums on a contract labelled an insurance policy were deductible.

In this episode I examine the key aspects of the judgment on the nature of the underlying transaction — substance over form, simulation and how courts characterise agreements for tax purposes — and conclude with what tax practitioners and advisers should take from the case.

Contact me at pieter@pvdz.co.za for feedback or tax advice. More South African tax resources: https://tax.pvdz.co.za

Zero-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 zero-rating. SARS issued a revised version of this interpretation note (Issue 5), nearly 10 years since the previous version. In this episode, I discuss zero-rating, the documentary requirements and some of the changes to Interpretation Note 31.
 You can contact me at ⁠pieter@pvdz.co.za⁠ if you have any feedback on the episode or require tax advice.
My website contains more resources and articles that may interest you  – ⁠https://tax.pvdz.co.za⁠. You are welcome to take a look!

SARS 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 ⁠pieter@pvdz.co.za⁠ if you have any feedback on the episode or require tax advice.
My website contains more resources and articles that may interest you  – ⁠https://tax.pvdz.co.za⁠. You are welcome to take a look!