This paper examines the investments made by China in key African countries and analyses the effects of such investment on the tax base of such African countries. The aim of this analysis is to determine whether the costs of such investment are commensurate to the benefits derived, or to be...

The term ‘trade’ is an important concept in the Income Tax Act, 58 of 1962 (the ‘Act’). Two central tenants of the Act are the concepts of gross income and deductions. On the one hand, trade is particularly relevant in a deductions context. On the other hand, trade also has a role to...

In Commissioner, South African Revenue Service v Brummeria Renaissance (Pty) Ltd 2007 (6) SA 601 (SCA) (Brummeria) the court held that the interest-free component of the loan between the parties was an amount which had accrued to the taxpayer, Brummeria Renaissance (Pty) Ltd. Moreover, the court...

The 1990s brought the announcement that the South African National Treasury plans to rewrite the entire Income Tax Act 58 of 1962. The rationale for this ambitious endeavour was founded on the practical difficulties encountered with applying an Act that what was little more than a collection of...

As the OECD’s efforts to implement Pillar Two become more concrete, it becomes more important to understand the implications of this instrument for African developing countries. This paper considers the possible responses available to a grouping of African countries in a bid to ensure that...

The COVID-19 global pandemic has devastated economies around the world – an impact which is minuscule compared to the toll it has taken on human lives. Daring to see that something good may come from this tragedy, this paper argues that there are clear synergies to be drawn between the health...