ENSafrica provides a snapshot of the latest tax developments in South Africa.


Advance tax rulings

  • Binding private ruling 304: debt reduction and subsequent liquidation of debtor
  • Binding private ruling 305: registration of units in the name of the beneficial owners
  • Binding private ruling 306: donation to a special trust

SARS publications

  • SARS publishes the Guide on Income Tax and the Individual (2017/2018)
  • SARS publishes the Draft Guide on Venture Capital Companies
  • Interpretation note 3 (issue 2): definition of residence in relation to a natural person – ordinarily resident
  • Interpretation note 9 (issue 7): small business corporations
  • Interpretation note 51 (issue 5): pre-trade expenditure and losses

Exchange control

  • Exchange control circular no. 11/2018
  • SARB publishes updated manuals


  • The Organisation for Economic Cooperation and Development (OECD) releases new guidance on the application of the approach to hard-to-value intangibles and the transactional profit split method under base erosion and profit shifting (BEPS) actions 8 and 10. The new guidance amends the specified sections of the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations
  • The OECD receives public comments on the scope of future revisions of chapter iv (administrative approaches) and chapter vii (intra-group services) of the Transfer Pricing Guidelines
  • The OECD and the African Tax Administration Forum have signed a renewal of their memorandum of understanding until June 2023 to continue to work together to improve tax systems in Africa
  • The OECD and the Intergovernmental Forum on Mining, Minerals, Metals and Sustainable Development (IGF) invite comments on a draft toolkit (The Hidden Costs of Tax Incentives in Mining), as part of the IGF-OECD programme to address BEPS in mining, that will help developing countries to identify and cost potential behavioural responses by mining investors to tax incentives

Discover more: ENSafrica tax revenews

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Taxand's Take

Taxpayers across South Africa should take note of the updates mentioned to ensure they remain compliant.

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Article tags

International Tax | South Africa

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