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Tax deductibility – SCA rules on financing fees

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On 7 September 2026, the Supreme Court of Appeal (SCA) handed down a significant judgment against the South African Revenue Service (SARS). The judgment confirmed that certain financing fees qualify for tax deductions under section 24J of the Income Tax Act, 58 of 1962.
Silent tax exit

Silent tax exit – an expensive assumption

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More and more high-net-worth South Africans living abroad realise that the assumption that physical emigration ends their South African tax exposure is not merely incorrect. It is also becoming increasingly expensive. Many expatriates become aware of the consequences only when they receive an unexpected and substantial assessment from the South African Revenue Service (SARS). The reality is that leaving the country is not a tax strategy. South Africans continue to make what can be described as a “silent exit”.

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