The Reserve Bank has now issued the revised Circulars to give effect to the changes proposed in the Budget Speech. These are outlined in Circular 6 to 14 issued on the 8th of April 2026.

• Circular 6 and 7: Single discretionary allowance updated to R2 million and the travel allowance for those under 18 to R200,000
• Circular 8 and 9: Increase in cash notes from R25,000 to R100,000 that can be moved across borders.
• Circular 10: The revised requirement introduces a uniform four-month time lag between payment to the foreign supplier and receipt of funds from the foreign importer, applicable to all merchanting trade transactions.
• Circular 11: Currently, Authorised Dealers may approve applications by South African business entities and/or individuals for the transfer abroad of miscellaneous payments against the production of documentary evidence confirming the amounts involved – the limit has been increased to R200,000.
• Circular 12: The transactional limit on credit cards has now been increased to R100,000 / transaction.
• Circular 13: Residents may now settle expenses using their CFC accounts with approval from the Financial Surveillance Department.
• Circular 14: Currently, Authorised Dealers may approve applications by residents to avail of inward foreign loans and foreign trade finance facilities from non-residents, subject to specific criteria which include interest rate thresholds. Under the new rules, Authorised Dealers may approve applications by residents to avail of these foreign borrowings, provided the interest rate is market related in the country of denomination and/or normal in the trade concerned. All other applicable criteria to these foreign borrowings remain extant.

Absa Bank Ltd and Another v Commissioner for the South African Revenue Service (CCT 72/24) [2026] ZACC 15 (22 April 2026)

We don’t include tax cases often. This one however can have some far-reaching consequences and broadens the anti-avoidance rules significantly. Back in 2021, ABSA won a case against SARS on a particular avoidance scheme it had implemented. The key facts are as follows:

• ABSA invested money in a RSA investment company.
• That investment company then invested those funds offshore, and through a number of different entities, ultimately brought it back into RSA via a structure that turned taxable interest into tax free preference dividends.

SARS taxed ABSA on the difference in return it received, arguing that the increased return as a result of the tax saving in the investment was a tax benefit and subject to the general anti avoidance rules (GAAR). ABSA, in the High Court case, argued that:

• They had no direct knowledge of how the underlying investments were structure, and therefore can’t be considered party to a GAAR transaction.
• They did not receive a tax benefit, they received an economic benefit, therefore GAAR should not apply.

This case eventually ended up in the Constitutional Court, where the majority agreed with SARS. The implications of this judgement are vast and far reaching. It means that if you invest your money, or a structure that is ultimately found to derive a tax benefit, and you subsequently get an economic benefit, that SARS could choose to tax you on that amount – even if you had no direct knowledge of the mechanism that gave rise to the tax benefit. All that is required is that you participate in the transaction.

There was one dissenting voice included in the judgement. Essentially Roger J agreed with the reasoning the High Court took in that knowledge should be required, and that there should be a distinction between an economic and a tax benefit. This case will certainly bring some interesting challenges to our tax planning environment – be careful what you sign up for, SARS is looking into these cases.