In a Government Notice published on 16 March 2015, the list of reportable arrangements has been significantly amended and expanded to include a number of new categories, including certain share buy-backs, contributions to non-resident trusts, the use of certain assessed losses and certain arrangements with non-resident insurers.  Excluded from the list of reportable arrangements are arrangements where the aggregate tax benefit does not exceed ZAR5 million.

It will be important to confirm if any of the new categories of reportable arrangements apply to a number of commercial transactions.