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Synopsis
A monthly journal, published by PwC South Africa, that gives informed commentary on current developments in the tax arena, both locally and internationally.
Through analysis of and comment on new laws and judicial decisions of interest, Synopsis helps executives to identify developments and trends in tax law and revenue practice that may affect their business.
In this edition:
Synopsis Tax today - August 2025
The global tax landscape has undergone significant changes with the introduction of the Pillar Two framework of the OECD which aims to ensure that multinational enterprises (‘MNEs’) pay a minimum level of tax on their global profits. South Africa has embraced these changes by implementing the Global Minimum Tax Act No. 46 of 2024 (‘GMT Act’), which aligns with the OECD’s Pillar Two rules. The first article explores the implications of these rules for South African MNEs, focusing on the advantages of safe harbour provisions and the integration of environmental, social, and governance (‘ESG’) reporting.
Our second article unpacks the legal and practical implications of section 45 of the Companies Act regarding financial assistance by a company to related or intergroup parties. Failure to ensure that intercompany loans are ‘fair and reasonable’ can expose directors to personal liability and reputational risk, particularly if the company later encounters financial difficulties. The section 45 requirement of ‘fair and reasonable’ is closely aligned with the core transfer pricing concept of ‘arm’s length’.
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