To Tax or not To Tax? Questioning Customer Loyalty Programmes

Authors Sumarie Swanepoel & Teresa Pidduck

ISSN: 1996-2185
Affiliations: Senior lecturers in the Department of Taxation, University of Pretoria
Source: South African Mercantile Law Journal, Volume 32 Issue 1, 2020, p. 75 – 98


South Africa, like many other countries, needs additional sources of tax revenues. Recent debate indicates that one potential source of revenue is the taxation of customer loyalty rewards in the hands of customers. The arguments for the taxation of these rewards have been put forward from a principled perspective and not from a legal basis. We argue that while the taxation of these rewards would increase tax revenue, legislative reform is required as there are strong arguments that the rewards are actually not taxable. We suggest tax reforms that attempt to provide certainty and equity in the treatment of such rewards as a whole in order to provide additional revenue for the fiscus.