Draft Documents for Public Comment

Draft Binding General Ruling

• Draft Binding General Ruling – Filing date of a return in case of a company’s change in financial year and year of assessment 

Explanatory Note
This binding general ruling provides clarity on the date for filing various returns when a company changes its financial year for purposes of the Companies Act and approval of a change in financial year and corresponding year of assessment is granted for income tax purposes.

Date published: 30 June 2026

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Draft Guide

Draft Guide to the Taxation of Crypto Assets

Explanatory Note
This guide considers selected provisions of the Act that are particularly relevant to crypto assets. It does not cover all the sections applicable to crypto assets and persons dealing with crypto assets, which, while not specifically referring to crypto assets or persons dealing in them, are nevertheless applicable.

The income tax system in South Africa is residence-based. This means that South African residents are, but for certain exclusions, subject to income tax on their worldwide income. This includes income derived both within and outside South Africa including income and capital gains from crypto assets listed on foreign trade exchanges.

Non-residents are potentially liable for income tax if South Africa is the source of proceeds which are of a revenue nature, or if the disposed asset meets the requirements of paragraph 2(1)(b)(i).

This guide focuses on the position of a South African tax resident taxpayer. However, the same principles apply to non-residents if the source- or paragraph 2 requirements are met.

For a detailed consideration see Interpretation Note 4 “Resident: Definition in relation to a Natural Person – Physical Presence Test”. A person, other than a natural person, for example, a company or a trust, will be a resident if the person is incorporated, established, or formed in South Africa or has its place of effective management in South Africa but it does not include any person who is deemed to be a resident of another country for purposes of the application of a double tax agreement between South Africa and that other country. For a detailed consideration on the meaning of “place of effective management” see Interpretation Note 6 “Resident: Place of Effective Management (Companies)”.

Date published: 1 July 2026

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