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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 - July 2025
As the financial markets in South Africa (‘SA’) anticipate the shift from the Johannesburg Interbank Average Rate (‘JIBAR’) to the SA Rand Overnight Index Average (‘ZARONIA’), market participants must prepare themselves for notable operational and tax implications. In our first article we explore the related tax consequences that taxpayers will need to address during this transition.
In our second article we look at how SARS is tightening the screws on the 2024 ownership requirement in section 8EA. On 22 December 2023, section 8EA(3) of the Income Tax Act 58 of 1962 was amended by the Taxation Laws Amendment Act 17 of 2023 through the insertion of an ownership requirement in respect of equity shares acquired for a ‘qualifying purpose’ using preference share proceeds. We examine how SARS has been interpreting and applying the ownership requirement in practice, with reference to Binding Private Rulings 413 and 414, and Binding Class Ruling 092.
In our third article we look at what “more likely than not” means in terms of IFRIC 23 versus the Tax Administration Act 28 of 2011. This article compares the practical interpretation to the meaning of “more likely than not” in terms of IFRIC 23 versus the TAA and seeks to provide some further clarity on the context in which the assessment of this term applies.
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