TAXTALK

TaxTalk – Issue 117 (March/April 2026): Tax Beyond Borders In this March/April 2026 edition, TaxTalk examines how tax systems are adapting to a world where business, capital and services increasingly move across borders with ease. Issue 117 brings together leading tax practitioners, policymakers and academics to explore the practical and policy implications of globalisation, digitalisation and intensified cross‑border enforcement. A central theme of this issue is the taxation of the digital economy, with detailed analysis of VAT on cross‑border digital services, destination‑based consumption taxes and the challenges faced by African tax administrations in taxing non‑resident suppliers without a physical presence. Contributors consider how fairness, revenue protection and voluntary compliance can be balanced in fast‑growing digital markets. The issue also provides in‑depth coverage of international corporate tax, including transfer pricing, the Global Minimum Tax (Pillar Two), evolving legislative frameworks and emerging trends in tax dispute resolution. Several articles draw on recent South African and international case law to illustrate how modern tax disputes increasingly hinge on procedural integrity, evidentiary quality and audit methodology, rather than technical interpretation alone. Further contributions examine the limits of double taxation agreements, highlighting how domestic anti‑avoidance rules can override expected treaty outcomes, and stressing the importance of comprehensive, cross‑jurisdictional due diligence. The growing tax risks associated with remote working arrangements are also explored, with practical guidance on permanent establishment exposure and the OECD’s 2025 commentary updates on home offices and service permanent establishments. Rounding out the issue, this edition looks beyond income tax to customs and global trade, analysing the revised WCO SAFE Framework and the increasing role of data‑driven customs compliance in an e‑commerce‑dominated trade environment. Issue 117 offers a forward‑looking and practical guide for tax professionals navigating an increasingly borderless, digitised and enforcement‑driven global tax landscape.