On 31 July 2020, the National Treasury published the 2020 Draft Taxation Laws Amendment Bill, which includes a proposed change to the definition of “affected transaction” for transfer pricing purposes. The proposed amended definition would be used to address situations when a tax benefit is indirectly derived by a South African resident as a result of its shareholding in a controlled foreign company (CFC). Public comments of the draft Law are invited until 31 August 2020. The proposed effective date of this amendment is 1 January 2021.
Related Posts
South Africa: Constitutional Court dismisses ABSA appeal, upholds tax avoidance recharacterisation
The Constitutional Court of South Africa has dismissed the appeal in Absa Bank Ltd and Another v CSARS (CCT 72/24), a case concerning a ZAR 1.9 billion structured investment scheme, in a judgment delivered on 22 April 2026. The dispute involved
Read MoreSouth Africa consults implementation of bilateral advance pricing agreements under DTAs
The South African Revenue Service (SARS) has initiated a public consultation, on 30 April 2026, on the implementation of bilateral advance pricing agreements (APAs) under double taxation agreements (DTAs), as part of an initial pilot phase of the
Read MoreSouth Africa: SARS introduces simplified compliance framework for partnerships
South African Revenue Service (SARS) announced, on 22 April 2026, a simplified compliance framework for partnerships through the introduction of a new Beneficial Owner Register IT3(BO), aimed at streamlining beneficial ownership reporting
Read MoreSouth Africa releases customs tariff amendment details for 2026
South Africa has released publication details for tariff amendments notice R7389 under the Customs and Excise Act, 1964, as set out in Government Gazette 54572. The notice, published on 23 April 2026, provides the formal framework for amendments
Read MoreSouth Africa: SARS announces scheduled digital platform maintenance, upgrades
The South African Revenue Service (SARS) has announced scheduled maintenance and upgrades to its digital platforms on 24 and 26 April 2026 as part of ongoing efforts to strengthen its technology infrastructure. SARS said the upgrades are aimed at
Read MoreSouth Africa updates income tax, VAT, carbon tax rules
South African President has signed the Taxation Laws Amendment Act 5 of 2026, amending the Carbon Tax Act, 2019 and related Schedules. The Act was passed on 31 March 2026 and published in the Government Gazette on 1 April 2026. It introduces
Read More