Synopsis

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  • Publication
  • October 09, 2026

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 - September 2026

In this edition, we unpack the Clicks Retailers litigation and the application of section 24C of the Income Tax Act, focusing on the contractual “sameness” requirement and Justice Wallis’s observations on whether ordinary stock purchases constitute future expenditure for purposes of the allowance.

We also consider the implications of VAT Case 22498, which highlights the need for a VAT apportionment method that is fair and reasonable and supported by credible and auditable evidence.

Finally, we examine the Devland Cash and Carry judgment, in which the High Court clarified that section 68 of the Tax Administration Act is not a general secrecy provision and affirms taxpayers' rights to access information relating to their own tax affairs.

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Adelheid Reyneke

Adelheid Reyneke

Senior Manager, PwC South Africa

Tel: +27 (0) 21 529 2200

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