In March, two notices were published in the Government Gazette prescribing regulations in respect of third party returns and the fixed penalty provisions that will be applicable in instances where there is non-compliance in submitting such returns.

Furthermore, in the 2017 Budget Speech, the Minister of Finance announced that South Africa intends to sign the multilateral instrument to implement BEPS measures in the country's tax treaty network so as to "reduce the scope for aggressive tax avoidance activities".

It can therefore be expected that further developments will occur as South Africa aligns its domestic legislation with current international standards.