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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.

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In this edition:

Synopsis Tax today - November/December 2025

The first article considers the Ditsoane Trading judgment which confirmed that there is no automatic access to the High Court for appeals and objections emanating from decisions taken in terms of sections 222 and 223 of the Tax Administration Act ("TAA") by the South African Revenue Service ("SARS"). Jurisdiction must also be established before any substantive rulings are made.

Furthermore, SARS has increased its focus on compliance with third-party data submission obligations. Our second article provides a structured overview of who must submit third-party data, the categories of information that must be reported and practical considerations for persons that may be impacted by these requirements. The requirements derive from Section 26 of the TAA and SARS’ public notices issued in June and November 2023. 

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Al-Marie Chaffey

Al-Marie Chaffey

Senior Manager , PwC South Africa

Tel: +27 (0) 11 797 5644

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