23/06/2026
SARS is targeting inter-spousal donation structures that have historically been used in exit tax planning by departing high-net-worth individuals.
Featured in Tax Chronicles (Issue 93 | 2026, pages 11 and 12), “SARS Moves to Limit Donation Tax Loophole for Departing High-Net-Worth Individuals” by Mbalenhle Mahlaba, Team Lead: Expatriate Tax at Tax Consulting South Africa, highlights how these arrangements are now under heightened regulatory attention.
The proposed changes focus on limiting the scope of the inter-spousal donations tax exemption where it intersects with changes in tax residency status, with particular emphasis on the timing of cessation of South African tax residency.
Read the full article to understand what is changing and what it could mean for your tax position: https://bit.ly/3SnWvY5