by VDT Attorneys | Jul 2, 2026 | Tax Advice, Tax collection efficiency, Tax filing, Tax planning
The principle is codified in section 164(1) of the Tax Administration Act 28 of 2011 (“the Act”), which provides that a taxpayer’s obligation to pay tax, and SARS’ authority to recover it, are not automatically suspended by the lodging of an objection or appeal. In...
by VDT Attorneys | Feb 4, 2026 | Tax, Tax Advice, Tax planning, Trust loans, Trusts
Section 7C of the Income Tax Act 58 of 1962 was introduced to address the perceived tax advantage of interest-free or low-interest loans to trusts when attempting to transfer wealth below market value. Where a connected person advances a loan to a trust at a rate...
by VDT Attorneys | Nov 24, 2025 | Reportable Arrangements, SARS, SARS disclosure rules, Tax, Tax Advice, Tax planning
A reportable arrangement is any transaction or structure that SARS believes could give rise to unusual or significant tax benefits. These include arrangements that result in a tax benefit of more than R5 million, the use of hybrid instruments that look like debt but...
by VDT Attorneys | Nov 12, 2025 | High-net-worth individuals, Mandatory balance sheet reporting, SARS, Tax collection efficiency, Tax planning
SARS established the High Wealth Individual Unit (HWIU) in 2021, recognising the need for a dedicated division to monitor and engage with affluent taxpayers who often possess complex financial structures, both locally and offshore. The HWIU forms part of SARS’s...
by VDT Attorneys | Jun 30, 2025 | Owing SARS money, SARS, SARS debt compromise agreement, Tax, Tax Advice, Tax planning
When a taxpayer is unable to pay its tax obligation to the South African Revenue Service (“SARS”), the taxpayer either has the choice to enter a deferral payment arrangement wherein they can arrange for a deferred payment plan, or the taxpayer may enter into a debt...
by VDT Attorneys | Apr 16, 2025 | Emigration, Financial Emigration, Tax, Tax Advisory, Tax planning
A pivotal aspect of successful financial emigration is the change in tax residency. South Africa employs two main criteria to assess tax residency: the Ordinary Residency Test and the Physical Presence Test. Ordinary Residency Test: This test determines whether a...
