SARS publishes this table for years ending 1 Apr 2026 – 31 Mar 2027.
Gross income limit: R 20 000 000
Section 12E has to be re-tested every single year. Fail any one test and the company pays the flat 27% for that whole year.
Tainted income: 1.9% of R 3 200 000 — ceiling is 20%.
Optional. Section 12E lets an SBC write assets off far faster than the ordinary wear-and-tear rates.
Estimates only — not tax advice. Based on SARS Interpretation Note 9 (Issue 7) and the SARS rates tables. Assessed losses, the section 20 loss-limitation rules, dividends tax on distributions, the section 12E(3) cost-of-moving rules, recoupments on disposal and SARS's list of permitted other shareholdings are not modelled. The turnover tax comparison is a separate elective regime with its own registration rules. Consult a registered tax professional for your company.
Income Tax Payable
At SBC rates on taxable income of R 650 000.
Effective Rate
13.0%
Marginal Rate
27%
SBC Saving
R 91 030
Tax on the same year, three different ways.
Turnover tax is not shown — qualifying turnover must be R 2 300 000 or less.
Every section 12E test, in the order SARS applies them.
Legal entity
A private company, close corporation, co-operative or personal liability company.
Shareholders are natural persons
Every holder of shares was a natural person throughout the year.
No other shareholdings
No shareholder held shares or an equity interest in another company.
Not a personal service provider
The company is not a personal service provider under the Fourth Schedule.
Gross income limit
Gross income of R 3 200 000 is within the R 20 000 000 limit.
20% business activity test
Investment and personal-service income is 1.9% of receipts and accruals plus capital gains — inside the 20% ceiling.
Your band is highlighted.
One dormant shell company costs you the whole year.
If any shareholder holds shares or an equity interest in any other company — even a dormant one, even for a single day — the company is not an SBC for that entire year of assessment. This is the single most common disqualifier, and it is usually accidental.Three employees switch the professional taint off.
Consulting, legal, accounting, engineering, IT and health income is only a "personal service" if a shareholder or connected person performs it personally and the company does not employ three or more full-time unconnected people in that business. Employ three, and the 20% cap stops biting.Interest and rent count against you.
The 20% test is not about profit — it is about receipts. Dividends, interest, royalties and rental from immovable property are all "investment income". A company parking cash in a call account can quietly breach the ceiling in a slow trading year.Qualifying is re-tested every single year.
An SBC in 2026 is not automatically an SBC in 2027. Both the gross income limit and the 20% test are annual, and the R20 million limit is pro-rated down if the company traded for less than 12 months.