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The imputability of ‘income on income’ under section 7(3) of the Income Tax Act
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Determining the residence of a trust : a South African income tax perspective
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Tax planning in the light of tax avoidance provisions in the South African income tax Act Section 103- as amended in the income tax Act No 36 of 1996
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An analysis of sections 11D(1)(A) and 11D(5)(B) of the income tax Act No. 58 of 1962 as amended
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Information exchange across borders and confidentiality rights of taxpayers from a South African perspective
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Analysis of the interaction between the income tax and capital gains tax provisions applicable to share dealers
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Tax revenue mobilisation : improving personal income tax compliance in South Africa
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The legal status of tax treaties in South Africa
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Tax avoidance and tax reduction within the framework of the South African income tax legislation, with special reference to the effect on the fiscus and to current anomalies and inequities
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The Income tax treatment of cryptocurrency trade in South Africa
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An analysis of merger and amalgamation transactions under the Companies Act 71 of 2008 and the Income Tax Act 58 of 1962
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A critical analysis of the interpretation of the term "associated enterprise" in provisions in South African double taxation agreement based on Article 9 of the Organisation for Economic Cooperation and Development's Model Tax Convention on Income and on Capital
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The treatment of section 24J instruments denominated in a foreign currency with regard to the categorisation as fixed or variable rate instruments and the interaction between section 24J, section 25D (foreign currency translation rules) and section 24I (gains and losses on foreign exchange transactions)
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An analysis of income from staking crypto assets paid to a non-resident in terms of the South African Income Tax Act No. 58 of 1962, and a tax treaty established on the OECD Model Tax Convention
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The deductibility of indirect empowerment measures relating to black economic empowerment (BEE) in terms of the income tax act
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A South African perspective on some critical issues regarding the OECD model tax convention on income and on capital, with special emphasis on its application to trusts
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Determining to what extent the “money-lender test” needs to be satisfied in the context of South African investment holding companies, focusing on the requirements of section 11(a) and 24J(2) of the Income Tax Act No. 58 of 1962

Author: Botha, Derek

Author: Mahuma, Keaobaka Percival

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A group income tax system for South Africa