Official source
Source domain: sanews.gov.za
Collected on 28 July 2026
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Green transactions under revised Section 45 framework
Businesses can reorganise group companies without interest-bearing debt and access tax-free asset transfer relief under Section 45 without requiring approval from SARS. This applies to legitimate transactions involving no debt funding.
The reorganisation of sections 44, 45 and 47 of the Act that do not involve interest-bearing debt will be able to use the relief without approval by SARS. This would fall under "green transactions."
Reference
https://www.sanews.gov.za/south-africa/gordhan-proposes-new-solution-section-45
Amounts
R 3 000 000 000, R 5 000 000 000
Amber transactions under revised Section 45 framework
Businesses can reorganise group companies using interest-bearing debt and receive automatic pre-approval under the revised Section 45 rules, enabling tax-free asset transfers while maintaining oversight.
"Amber transactions" comprise reorganisations that use interest-bearing debt that is subject to automatic pre-approval.
Investigation into aggressive pre-existing transactions
SARS continues to investigate past transactions that were designed to avoid paying fair taxes, particularly those involving aggressive tax avoidance schemes in intra-group dealings.
Gordhan said that SARS will continue to investigate a number of pre-existing aggressive transactions that deliberately avoid paying their fair share of the tax burden.
