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As part of the annual review, the following corporate tax policy and administrative adjustments were proposed on 23 February 2022:

  • The 2021 amendments to the definition of contributed tax capital are planned to become effective on 1 January 2023. These amendments will be revisited during the 2022 review cycle to evaluate the impact thereof;
  • The Legislator intends to introduce amendments to the corporate tax reorganisation provisions to further refine said provisions;
  • The Legislator plans to introduce amendments to clarify that the assessed loss limitation provisions should be applied before taking into account any mining capital expenditure;
  • Legislative amendments will be proposed to clarify that the provisions of section 11(e) cannot be applied where the relevant asset was acquired by a government grant in kind;
  • Legislative amendments will be introduced to clarify certain aspects of the controlled foreign company provisions;
  • Further amendments to section 72 of the VAT Act in respect of decisions regarding the application of provisions that result in difficulties, anomalies or incongruities will be made;
  • The regulations prescribing electronic services for VAT purposes will be reviewed to ensure that the scope is in line with the OECD BEPS Action 1 Report;
  • Inclusion of relevant legislative amendments to provide for an enabling framework for advance rulings in respect of customs and excise related matters to be made;
  • The provisional tax system will be reviewed to ensure that it is in line with international developments;
  • The introduction of a possible VAT registration exemption for non-resident suppliers that supply electronic services which exceed R1 million but that is supplied on a once-off basis;
  • The relevant legal framework will be reviewed to allow SARS to conduct joint audits with foreign revenue authorities; and
  • The proposed imposition of understatement penalties where an employer abused the provisions of the Employment Tax Incentive Act, where such abuse resulted in a reimbursement by SARS.

if you require advice on the proposed amendments on your corporate tax compliance, corporate tax planning and  corporate tax reorganisation, and please follow us on social media  to keep track of tax-related developments.