Tax Break: South African tax for professionals

Professor Pieter van der Zwan | South African Tax Specialist
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Tax Break is a podcast for any professional who works with South African tax regularly. This includes tax practitioners, tax professionals, financial managers (FMs), financial directors (FDs), CFOs, accountants, auditors, lawyers and corporate finance advisors. The host is Professor Pieter van der Zwan, a South African chartered accountant, who lectures the masters programme in tax at a South African university. He has 20 years experience in advising companies, high net worth individuals, accountants, lawyers and corporate finance professionals on South African tax and IFRS. In each episode he discusses a topic or a recent development in South African tax including new cases, changes to the legislation, SARS guidance and topics that often surface in his consulting practice. And each episode is only 10-15 minutes long, just enough for you to listen to during your coffee break!

  1. 3d ago

    Are self-insurance premiums tax deductible? The Meiring Citrus judgment

    Are self-insurance premiums deductible? In this episode of Tax Break, I discuss the deductibility aspect of the Western Cape High Court judgment in CSARS v Meiring Citrus (Pty) Ltd.  I cover: The two grounds that SARS abandonedThe court’s conclusion as to whether the taxpayer actually incurred expenditureWhy I disagree with the court's position on expenditureThe court’s position on the capital nature of the premiums paid.If you work with South African tax as an auditor, accountant, lawyer, wealth planner or corporate finance professional, this episode is for you. Contact me at pieter@pvdz.co.za for feedback or tax advice. More resources at https://tax.pvdz.co.za. Keywords: self-insurance premiums, section 11(a) deduction, Meiring Citrus, capital in nature, expenditure actually incurred, Labat Africa, section 23L, experience account, South African tax, Income Tax Act, Western Cape High Court, SARS

    Are self-insurance premiums tax deductible? The Meiring Citrus judgment

  2. Aug 20

    Section 99 prescription: When can SARS reopen a tax assessment after three years? CSARS v Meiring Citrus

    When does prescription protect taxpayers from SARS issuing additional assessments? Section 99 of the Tax Administration Act generally bars SARS from issuing an additional assessment more than three years after the original assessment issued by SARS. Section 99(2) lifts that bar where the tax was not assessed due to fraud, misrepresentation or non-disclosure of material facts. In this episode of Tax Break, I discuss the prescription aspect of the Western Cape High Court judgment in CSARS v Meiring Citrus (Pty) Ltd. SARS issued additional assessments roughly three and a half years after the original 2017 assessment, relying on the non-disclosure of notional interest of R1 197.52 on an experience account under a structured self-insurance policy, and a misrepresentation of the nature of the agreement. I cover: The timeline of assessments, verifications and the audit, and why the dates matter under section 99The two questions in section 99(2): is a listed conduct present, and did it cause the tax not to be assessedThe difference between the Tax Court and High Court analysisAssessment of the materiality of a non-disclosureOpen questions: the role of information provided during a verification, and where taxpayer disclosure ends and SARS's duty to ask for more information beginsPractical lessons on completing the ITR14 accurately, including income statement and balance sheet line items, and why responses to verification requests should not be underestimatedIf you work with South African tax as an auditor, accountant, lawyer, wealth planner or corporate finance professional, this episode is for you. Contact me at pieter@pvdz.co.za for feedback or tax advice. More resources at https://tax.pvdz.co.za.  Keywords: prescription, section 99, Tax Administration Act, additional assessment, SARS audit, Meiring Citrus, non-disclosure, misrepresentation, ITR14, South African tax

    Section 99 prescription: When can SARS reopen a tax assessment after three years? CSARS v Meiring Citrus

  3. Aug 13

    2026 draft TALAB: PAYE for foreign employers with SA permanent establishments, provisional tax penalties and VDP changes

    The National Treasury published the 2026 draft Tax Administration Laws Amendment Bill (draft TALAB) for public comment on 30 July 2026. In this episode, I discuss three proposed amendments with clear practical impact for South African taxpayers and their advisors, two of which are favourable to taxpayers. The topics covered: ·       Employees' tax (PAYE): a proposal to narrow the withholding obligations of foreign employers with permanent establishments (PEs) in South Africa ·       Provisional tax: aligning underestimation penalties under paragraph 20 of the Fourth Schedule with actual payments made ·       Voluntary disclosure programme (VDP): broadening the relief available under the Tax Administration Act Contact me at pieter@pvdz.co.za for feedback or tax advice. More resources at https://tax.pvdz.co.za.

    2026 draft TALAB: PAYE for foreign employers with SA permanent establishments, provisional tax penalties and VDP changes

  4. Aug 6

    2026 Draft Tax Bills: CFCs, dividend stripping, interest deductions, VAT on leasehold improvements

    South Africa’s National Treasury published the 2026 draft tax law amendments for public comment on 30 July 2026. Although proposals are technical, tax practitioners and CFOs need to assess whether their businesses or clients are affected. In this episode I analyse four key proposals: the interaction between the controlled foreign company (CFC) rules and the domestic treasury management company (DTMC) regime for translating CFC income, the clarification of the dividend stripping anti-avoidance rules, the withdrawal of the alignment between the interest deduction limitations in sections 23M and 23N of the Income Tax Act, and the proposed VAT changes for leasehold improvements. Contact me at pieter@pvdz.co.za for feedback or tax advice. More South African tax resources: https://tax.pvdz.co.za .

    2026 Draft Tax Bills: CFCs, dividend stripping, interest deductions, VAT on leasehold improvements

  5. Jul 30

    CSARS v Meiring Citrus: substance over form, simulation and the deductibility of insurance premiums

    Does the label on a contract determine its South African tax consequences? If you call an agreement a loan, are the payments deductible interest? If you call it a lease, are the outflows deductible rent? In CSARS v Meiring Citrus the Western Cape High Court considered whether premiums on a contract labelled an insurance policy were deductible. In this episode I examine the key aspects of the judgment on the nature of the underlying transaction — substance over form, simulation and how courts characterise agreements for tax purposes — and conclude with what tax practitioners and advisers should take from the case. Contact me at pieter@pvdz.co.za for feedback or tax advice. More South African tax resources: https://tax.pvdz.co.za

    CSARS v Meiring Citrus: substance over form, simulation and the deductibility of insurance premiums

  6. Jul 23

    Are your zero-rated supplies really zero-rated?

    Zero-ratings are complex and often underestimated by taxpayers and their advisors. The exposure may be significant if you get it wrong, especially on recurring transactions. Interpretation Note 31 is an essential part of applying a zero-rating. SARS issued a revised version of this interpretation note (Issue 5), nearly 10 years since the previous version. In this episode, I discuss zero-rating, the documentary requirements and some of the changes to Interpretation Note 31.  You can contact me at ⁠pieter@pvdz.co.za⁠ if you have any feedback on the episode or require tax advice. My website contains more resources and articles that may interest you  – ⁠https://tax.pvdz.co.za⁠. You are welcome to take a look!

    Are your zero-rated supplies really zero-rated?

  7. Jul 16

    Taxation of crypto assets

    SARS issued a draft guide on the taxation of crypto assets. In this episode, I discuss a few aspects of this draft guide that I believe offer valuable insights into SARS’ position on these assets. You can contact me at ⁠pieter@pvdz.co.za⁠ if you have any feedback on the episode or require tax advice. My website contains more resources and articles that may interest you  – ⁠https://tax.pvdz.co.za⁠. You are welcome to take a look!

    Taxation of crypto assets

  8. Jul 9

    Section 42: What is it not? (Part 2)

    Section 42 of the Income Tax Act provides relief for asset-for-share transactions. In this episode, I discuss some anti-avoidance rules to consider when dealing with asset-for-share transactions. You can contact me at ⁠pieter@pvdz.co.za⁠ if you have any feedback on the episode or require tax advice. My website contains more resources and articles that may interest you  – ⁠https://tax.pvdz.co.za⁠. You are welcome to take a look!

    Section 42: What is it not? (Part 2)
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About

Tax Break is a podcast for any professional who works with South African tax regularly. This includes tax practitioners, tax professionals, financial managers (FMs), financial directors (FDs), CFOs, accountants, auditors, lawyers and corporate finance advisors. The host is Professor Pieter van der Zwan, a South African chartered accountant, who lectures the masters programme in tax at a South African university. He has 20 years experience in advising companies, high net worth individuals, accountants, lawyers and corporate finance professionals on South African tax and IFRS. In each episode he discusses a topic or a recent development in South African tax including new cases, changes to the legislation, SARS guidance and topics that often surface in his consulting practice. And each episode is only 10-15 minutes long, just enough for you to listen to during your coffee break!

Information

  • Creator
    Professor Pieter van der Zwan | South African Tax Specialist
  • Years Active
    2024 - 2026
  • Episodes
    89
  • Rating
    Clean
  • Copyright
    © Professor Pieter van der Zwan | South African Tax Specialist
  • Show Website
    Tax Break: South African tax for professionals