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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 - October 2026
The October edition of Tax Synopsis is now available, featuring insights into recent South African tax developments.
In this edition, we consider the Supreme Court of Appeal’s judgment in Commissioner for the South African Revenue Service v Cornucopia Trust, which rejected SARS’s restrictive interpretation and held that the raising fees in question were “similar finance charges”, deductible under section 24J.
We also conclude our series on the general anti-avoidance rules in Company AF (Pty) Ltd and Others v CSARS, focusing on the “tainted elements” requirement. The article considers the Tax Court’s findings on abnormality, lack of commercial substance, rights or obligations that would not normally be created between persons dealing at arm’s length, and the misuse or abuse of the provisions of the Income Tax Act.
Finally, we examine the transfer pricing implications of intra-group financial guarantees, including the distinction between implicit group support and explicit guarantees, whether a guarantee provides genuine economic benefit, and when an arm’s-length fee may be justified.
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