South Africa tables 2026 tax bills with CFC, SEZ and VAT changes

The package comprises the Taxation Laws Amendment Bill 2026 (B32—2026), Tax Administration Laws Amendment Bill 2026 (B33—2026) and Rates and Monetary Amounts and Amendment of Revenue Laws Bill 2026 (B34—2026). SARS confirms that all three were introduced in the National Assembly on 21 October. They remain proposals: the bills’ commencement clauses do not dispense with parliamentary passage and presidential assent.^[1][2]

CFC currency and domestic SEZ pricing

For multinational groups, B32 would change how controlled foreign companies translate net income. The computation would start in the CFC’s functional currency. An ordinary resident shareholder would translate the result into rand using the foreign-year average exchange rate, while a domestic treasury management company would translate it into its own functional currency. The measure would apply to CFC foreign tax years beginning on or after 1 January 2027.^[3]

B32 would also bring specified domestic connected-party dealings into Income Tax Act section 31. Transactions between a qualifying company trading in an approved special economic zone and a connected resident that is not itself a qualifying company would have to reflect arm’s-length terms. Where SARS adjusts one party, the other party’s taxable income would receive a corresponding arm’s-length calculation. The rule would apply for years of assessment beginning on or after 1 January 2027.^[3]

VAT platforms, property and filing

VAT changes would affect platforms and property arrangements from 1 April 2027. An intermediary facilitating electronic services would be treated as the supplier by default unless it and the principal agree in writing that the principal will account for the supply. Joint and several liability would apply where that written agreement is absent. B32 would also extend the leasehold-improvement adjustment to non-vendor lessors, requiring a prescribed declaration and payment within 30 days. Separately, B33 would move the VAT return and payment deadline to the last business day of the first month after the tax period.^[3][4]

Energy, carbon tax and rates

Other business measures include recognition of qualifying renewable-energy roads and fences as mining capital expenditure, extension of rehabilitation-fund rules to nuclear-licensed facilities, and replacement of the commercial and institutional carbon-tax threshold with 25,000 tonnes of carbon-dioxide-equivalent emissions a year. B34 would retain the 27% general company rate and 15% qualifying SEZ rate, while increasing the turnover-tax eligibility ceiling from R1 million to R2.3 million. Groups should track the bills’ parliamentary progress and distinguish retrospective 2026 measures from provisions scheduled for 2027.^[3][5]