Comments on the draft Note must be submitted by 10 October 2025.
The South African Revenue Service (SARS) has initiated a public consultation on a draft interpretation note on the income tax exemption applicable to bodies corporate, share block companies, and other associations of persons.
This Note provides guidance on the interpretation and application of section 10(1)(e). 2. Background Section 10(1)(e) exempts from income tax the levy income of a body corporate, a share block company, and any other association of persons. The section also provides for a basic exemption. Expenditure incurred in respect of the levy income is not an allowable deduction.
The draft Note is released for comment, covering technical updates including definitions of associations of persons, the Close Corporations Act, carry-forward of assessed losses, and retrospective approval of associations of persons.
The SARS Draft Interpretation Note 64, Issue 5, provides updates on taxation rules for various entities and activities, including corporate bodies, share block companies, and qualifying associations of persons; it covers prohibited transactions, income exemptions, taxable income calculation, exemption applications, other taxes (donations, dividends, capital gains, provisional), objections and appeals, reporting obligations, and representative taxpayers.
The deadline for submitting comments on the draft Note is 10 October 2025.
Comments should be submitted to policycomments@sars.gov.za.
