The submission outlines several legislative misalignments and outdated provisions affecting employees, employers, and foreign workers, and proposes targeted amendments to improve clarity, fairness, and administrative efficiency. It highlights inconsistencies between foreign employers’ obligations to withhold PAYE, UIF, and SDL—where UIF and SDL apply regardless of permanent establishment status—but PAYE obligations do not, and recommends aligning these laws to distinguish clearly between local and foreign employers. It proposes introducing a single designated employer registration for group companies to avoid duplicate registrations and administrative penalties where one company already centrally manages payroll taxes for the group. It also calls for legislative updates to accommodate the new digital nomad visa regime, noting that immigration regulations conflict with Income Tax Act requirements for who must register as a taxpayer, and requests amendments to sections 66 and 67 to resolve this conflict. Finally, the submission recommends updating several outdated Seventh Schedule exemption thresholds—such as for employer-provided accommodation, long-service awards, and low- or interest-free housing loans—which no longer reflect economic realities, proposing modernised values, CPI-linked automatic adjustments, and a comprehensive review cycle to restore the policy intent and reduce inequitable fringe-benefit taxation.
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