• 2022 Budget speech proposals and monetary rates and amounts
• Selective amendments promulgated during 2021, becoming effective 2022, to be discussed in detail include:
o Employees’ Tax:
 Curbing the abuse of the Employment Tax Incentive
 Estimated assessments and penalties
 Long service awards and fringe benefits
o VAT:
 New Section 18D for property developers and temporary letting
o Income Tax:
 Corporate restructuring, value shifting and anti-avoidance rules
 Limitation of interest deductions for companies
 Amendments concerning contributed tax capital
 Amendments concerning controlled foreign companies
o General and Tax Administration:
 Timing of disposals by deceased estates
 Disposals of rights to assets and deemed disposals
 Estimated assessments and taxpayer submissions to oppose it
• Selective responses and decisions from National Treasury to commentary on the draft legislation published in 2021, including withdrawals and postponement of proposed amendments, including:
o The taxation of retirement benefits upon ceasing to be resident
o The ringfencing of assessed losses for companies
o The anti-avoidance amendments relating to loans between trusts
• Update on the emigration and TCS process, including an overview of the related amendments that have become effective or were otherwise withdrawn
• Selective interpretation notes and SARS rulings issued during 2021 and 2022 that had a significant impact on taxpayers:
o Interpretation Note 28: Deductibility of home office expenses (including an overview of the updates, submissions by stakeholders and FAQ’s)
o Draft Interpretation Note on the meaning of “readily apparent undisputed error”, including an overview of the submissions by stakeholders
o Binding General Ruling 57: Consideration for VAT purposes and transfer duty for second-hand properties
• Selective court rulings from 2021 and 2022 that had a significant impact on the tax environment:
o VAT: Rappa Resources v CSARS – entitlement to a VAT refund
o VAT: Tourvest Financial Services v CSARS – establishing the exempt nature of supplies
o Income Tax: Clicks Retailers v CSARS – deductions in terms of Section 24C
o Tax Administration: Arena Holdings and others v CSARS – disclosure of taxpayer information in the public’s interest
o Tax Administration: Purveyors SA Mine Services v CSARS – voluntary nature of disclosure made under a VDP
o Income Tax: IT 24790 – deductibility of leave and bonus accruals
• Recent issues taken up with SARS by regulatory bodies on operational matters and other matters of interest

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