The SAIT Personal and Employment Taxes WG submission (12 September 2025) provides comments on the Draft Taxation Laws Amendment Bill, 2025, covering several proposals: it notes limited impact but no objections to including foreign employment income in the remuneration proxy; supports amendments allowing retirement fund transfers to non-member spouses under religious tenets; raises strong concerns about lowering the threshold for ring-fencing of assessed losses, warning of disproportionate effects on middle-income taxpayers, increased verification burdens, and fairness issues, while recommending targeted measures and relief; fully supports exempting child maintenance payments made from after-tax income; welcomes alignment of death benefit taxation across retirement fund components; cautions against repealing the exemption for foreign retirement fund benefits due to risks of double taxation, discouraging repatriation, and reducing South Africa’s appeal to foreign retirees, and recommends transitional relief, carve-outs, and a later effective date; and lastly, highlights unresolved issues on non-resident employer PAYE registration, SDL/UIF misalignments, and requests clarification on employer registration for company groups.
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