Tax

South Africa’s Medium-Term Budget Policy Statement (MTBPS) is a key mid-year fiscal update that reviews performance against the February Budget. It also reallocates spending where needed and recalibrates priorities for the year ahead.

If South African tax were a fable, it would feature three enduring characters: the weary taxpayer, the watchful SARS, and the elusive concept known as certainty. All three appear in our legislation, but only one consistently shows up in practice - SARS.

With the South African Rand (ZAR) hovering at its strongest level since the start of 2025, at around R17.30 to the US dollar, many high-net-worth individuals (HNWIs) are enquiring about urgently moving funds offshore before year-end to take advantage of the currency’s current strength.

Many South Africans working from home are asking which home office expenses they can claim as tax deductible items. They also want to know how to claim them correctly. This question is especially relevant for the growing number of South African employees working remotely for global companies. Increasingly, these employees are turning to tax practitioners for guidance regarding home office tax claims.

For many taxpayers, especially expatriates, managing South African tax obligations from a distance can be complicated. Years may pass without any direct interaction with the South African Revenue Service (SARS). During that time, key details such as contact information, banking details and tax number status often become outdated.

South Africa’s tax base continues to evolve in striking ways. Recent South African Revenue Service (SARS) figures show a growing trend. The number of individuals registered for tax increased from 25.9 million in 2023 to 27.1 million in 2024. Yet, only 7.6 million of these individuals were expected to file a return.

A recent Gauteng High Court judgment has brought clarity on the interaction between consolidation orders under the Companies Act and the South African Revenue Service’s (SARS) powers to raise tax assessments. In Prinsloo and Others N.O. vs CSARS and Another (020214-2023) [2025] ZAGPJHC (29 August 2025), the court quashed an attempt by liquidators to set aside SARS assessments against a Ponzi scheme.

National Treasury has proposed three major amendments affecting portfolios of Collective Investment Schemes (CISs) in the draft Taxation Laws Amendment Bill, 2025 (TLAB). The National Treasury’s vicious crackdown aims to close several tax loopholes and strengthen compliance within the CIS framework.

For many high-net-worth South Africans living and working abroad, the call of home is growing stronger. Whether prompted by family ties, lifestyle choices or a renewed focus on local business opportunities, the decision to return is often as emotional as it is practical.

The Supreme Court of Appeal’s recent decision in Assmang (Pty) Ltd vs The Commissioner for the South African Revenue Service (SARS) has sent a clear and sobering message to taxpayers. In tax law, substance always trumps form. While this principle is not new, its application in the context of diesel refunds highlights the immense peril taxpayers face. The Assmang diesel refund case illustrates this danger vividly.