The SAIT Wealth and Family Business Technical WG submission (12 September 2025) comments on the Draft Taxation Laws Amendment Bill, 2025, focusing on two key issues: first, it raises concerns about the proposed repeal of the foreign pension exemption in section 10(1)(gC)(ii), noting risks of inequitable double taxation, lack of clarity on the treatment of lump sums versus annuities, and potential punitive effective tax rates, while recommending transitional relief, clearer definitions, and adjustments to align with fairness principles; second, it critiques amendments to sections 7(5) and 25B regarding the taxation of trusts, warning that removing the wording “subject to section 7” could disrupt attribution rules, cause mismatches with double tax agreements, and even result in double taxation, and recommends retaining the current framework or clarifying the intent to prevent uncertainty and unintended consequences.
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