According to Tax Consulting South Africa, the proposed amendments aim to strengthen tax administration, eliminate loopholes in taxation, and introduce technical changes to existing tax legislation.
South African citizens may face changes to donation tax, VAT rules, tax credits for medical programs, and tax refund processes after the Ministry of Finance and the South African Revenue Service (SARS) published the draft Tax Legislation Amendment Bill for 2026 (TLAB) and the draft Tax Administration Laws Amendment Bill (TALAB) for public comment.
These bills, published on July 30, 2026, contain a number of tax and administrative proposals that were announced in the 2026 budget. It is important to note that they are not yet law and are available for public comment until August 28, 2026.
After the consultation period, the Ministry of Finance and SARS will consider the submitted comments before the final approval of the legislation and its submission to Parliament.
The accompanying memorandum details the proposed changes affecting personal income tax, savings and employment, business, business incentives, financial institutions, international tax matters, Value Added Tax (VAT), and the Carbon Tax Act.
Key Proposed Tax Changes
Donation Tax
The draft legislation proposes to limit the exemption from donation tax between spouses if the receiving spouse is not a South African tax resident. This measure is intended to prevent the use of changes in tax residency to evade donation tax and capital gains tax.
Special Economic Zones
New transfer pricing rules are proposed for certain transactions between companies operating in Special Economic Zones (SEZs) and related entities outside these zones.
Medical Program Tax Credits
The bills provide for the expansion of the right to receive tax credits for members of certain limited medical programs by legally defining such programs in tax legislation.
Controlled Foreign Companies
The proposed amendments aim to unify currency transfer rules between Controlled Foreign Companies (CFCs) and Internal Asset Management Companies. If these changes are approved, they are expected to come into effect on January 1, 2027.
VAT on Second-hand Goods
The draft legislation introduces additional documentation requirements for sellers dealing in second-hand goods. These measures are intended to reduce fraudulent VAT claims while bringing tax requirements into compliance with the Second-hand Goods Act and its regulations.
SARS Refunds
The proposals will allow banks to verify certain tax refund amounts before or after payment to identify suspicious transactions and assist SARS investigations.
Tax Compliance Status
The draft Tax Administration Laws Amendment Bill also seeks to address issues arising when taxpayers may not be recognized as taxpayers, while requests for payment suspension or penalty relief are still being considered. The proposed changes remain subject to public comment until they are considered by Parliament.



