The Wealth & Family Business Tax Technical Work Group’s Annexure C submission highlights two critical issues: the risk of double taxation arising from trust distributions due to the interplay of Section 7C donations tax, estate duty, and attribution rules, which complicates generational wealth planning and creates unintended tax burdens; and the need for legislative amendments to section 18A of the Income Tax Act to align with international agreements, enabling United Nations entities in South Africa to receive tax-deductible donations without compromising diplomatic privileges. The proposals aim to ensure fairness, prevent punitive tax outcomes, and support compliance while facilitating global development initiatives.
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