Davey’s Locker

Editor’s Note: In this newsletter we address salient features of the National Budget, 25 February 2026, pertaining to the 2026/27 tax year. Tax relief is granted to individuals for personal tax thresholds, capital gains tax thresholds and the donations tax annual...

Editor’s Note: In this sixth newsletter for 2025 we consider the following: Income transfers to Non-Residents : New SARB/SARS Excon Criteria. Foreign Pensions Proposal Withdrawal – Tax Exemption to Remain. SARS Draft IN on “Readily Apparent Undisputed Error”. Tax...

Editor’s Note: In this fifth newsletter for 2025 we consider the following: Tax and ConCourt Jurisdiction Foreign Pensions – Tax Exemption Withdrawal Proposal Section 20A Ringfencing of Assessed Losses Tightening Proposal Hybrid Equity Instrument Proposal Reprieve –...

Editor’s Note: In this fourth newsletter for 2025 we consider the following: Fraud of Funds by Inter-Bank Transfer Filing Season Tax Ombud Media Release, 7 July 2025 SARS Ins, BGRs, VRs, and Guides Noter-Up Tony Davey – Editor | Duncan McAllister – Co-Editor To...

Editor’s Note: In this third newsletter for 2025 we consider the following: VAT Increase Withdrawn Budget Newsletter No. 2.2025, status quo. Foreign Pensions – Budget Proposal to withdraw the tax exemption Trust Taxation – Budget Proposal to clarify technical...

In this newsletter we address salient features of the National Budget, 12 March 2025. Tony Davey – Editor | Duncan McAllister – Co-Editor | Werner Vos – Consultant BUDGET SPEECH 2025/26 TAX YEAR INDIVIDUALS There are no changes to the rates of tax and rebates. The...

Editor’s Note: In this first newsletter for 2025 we consider the following: Collective Investment Schemes (CIS) Tax Treatment Review, Amending Acts Promulgated, Retirement Funds now Formally Excluded from the Exit Charge Under Section 9H, Another Concourt Tax Case:...

Editor’s Note: In this seventh newsletter for 2024 we consider the following: The Thistle Case finality – Concourt Judgment Non-Submission of a Tax Return and Penalties: Administrative Penalties or the USP? Tax Practitioners further Statutory Recognition The Office of...

Editor’s Note: In this sixth newsletter for 2024 we consider the following: Right of Appearance in Tax Court Expanded ADR Process accelerated to Objection Stage Introducing a “new” Ground of Appeal, post original Objection SARS Interpretation Notes (INs), Draft Ins,...

Editor’s Note: In this fifth newsletter for 2024 we consider the following: Constitutional Court Coronation Judgment Poulter v SARS: The next instalment (Guest Author) Dissipation of Tax Debt – Third Party Liability The new Two-Pot Retirement System, 1 September 2024...

Editor’s Note: In this fourth newsletter for 2024 we consider the following: RSA Resident Trusts with non-resident beneficiaries revisited Constitutional Court Tax Jurisdiction The Tax Court – Status and Representation Determined (Guest Author) Musings on SARS Advance...

Editor’s Note: In this third newsletter for 2024 we consider the following: Soft Loans to Non-Resident Trusts revisited – Budget Review 2024 Constitutional Court judgments eagerly awaited in Thistle Trust and Coronation cases Foreign Employment PAYE Limitations Global...