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BUDGET SPEECH 2017

BUDGET SPEECH 2017:

THE KEY TAKEOUTS AND IMPLICATIONS Dave Mohr & Izak Odendaal, Old Mutual Multi-Managers

Since 2009, the large budget deficits have been funded by borrowing, and an increasing share of Government’s finances is spent on servicing debt, crowding out other areas of spending. This is not sustainable.

BETTER GROWTH OUTLOOK HELPS FISCAL CONSOLIDATION PLANS

However, the task of narrowing the sizable budget deficit has been hampered by economic growth that not only slowed down, but slowed more than expected year after year. Economic growth was barely positive in 2016 and, unsurprisingly, tax revenues have been under pressure (since tax is basically Government’s claim on economic activity, it rises and falls with the business cycle). The first input in analysing the Budget is the economic forecasts on which the Treasury bases its revenue and spending assumptions. If these forecasts are unrealistic, the Budget itself loses credibility. Gross domestic product growth of 1.3% is expected in 2017, followed by 2% in 2018 and 2.2% in 2019 (Chart 1). These forecasts are unchanged from the October Medium-Term Budget (MTB), the first time in five years that growth estimates have not been cut. If commodity prices remain at current levels amid stronger global economic growth, these forecasts might be too low, in which case the task of closing the deficit becomes easier.

TAX CHANGES: WHO FEELS THE PAIN? The question on everyone’s lips before the Budget was where the Minister would get the additional R28 billion in tax revenue in the coming fiscal year and R15 billion in fiscal 2018/19. Tax revenue for the current fiscal year is also expected to be behind schedule due to a decline in tax buoyancy (the amount of tax you get for each unit of economic growth). This has necessitated the following tax increases: • A new top personal income tax bracket has been introduced for individuals earning above R1.5 million per year. This will raise an additional R4.4 billion and increase the progressive characteristic of the tax system. • The bad news for middle-income taxpayers is that there will be limited bracket creep relief of only R2.5 billion (down from R5.5 billion last year and R8.5 billion the year before).

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last year) while the Road Accident Fund levy increases

DEFICIT PROJECTIONS: STICKING TO THE PLAN

by 9 cents per litre. It was proposed that the VAT zero-

As growth has declined and persistently missed forecasts since 2012,

rating on fuel be removed in 2018.

the narrowing deficit was postponed year after year (Chart 2). Given

• The fuel levy increases by 30 cents per litre (same as

• Dividend Withholding Tax (DWT) increases to 20%,

global investors and ratings agencies’ tight leash on South Africa,

which should raise R6.8 billion in additional revenue.

particularly with regard to the concerns around political interference at the Treasury leadership, there was little option to push out fiscal

• “Sin” taxes (excise duties on cigarettes and alcoholic

consolidation plans again. Sticking to the deficit targets as outlined

drinks) are to increase again, raising an additional

in the October MTBPS is therefore crucial.

R1.9 billion.

The targets remain at 3.4% for the current fiscal year and 3.1% for

• A tax on sugary beverages will be implemented later

2017/18 but there is marginal slippage in the outer years with

this year once details are finalised.

the deficit declining to 2.8% in 2018/19 (previously 2.7%) and

SPENDING: CUTTING THE FAT

2.6% in 2019/20 (2.5%).

Government is sticking to the expenditure ceiling – a cap on

IMPLICATIONS

non-interest spending imposed in 2012. There is no further

The 2017 Budget retains a commitment to narrowing the budget

reduction in the expenditure ceiling beyond the R26 billion

deficit to an internationally acceptable level of 2.6% of GDP over

announced in the October mini-budget. No big changes in

the medium term and stabilising the government debt to GDP ratio

spending priorities have been made so spending discipline

through a combination of additional tax revenue increases and

will come from trimming the fat. Non-interest spending is

slower growth in overall spending (with outright cuts in some areas).

expected to remain at a steady 26.2% share of GDP (but

Fortunately, unlike the previous four years, the 2017 Budget comes

interest payments will rise by 10% per year).

against a more favourable global climate (firmer commodity prices

The wage bill is expected to grow by 7.2% over the three-year

and positive sentiment towards emerging markets) and a somewhat

framework period, slightly below overall spending growth of

improved local economic outlook. In the short term, fiscal consolidation is a drag on economic growth, but should not derail the recovery.

7.5%, but the headcount in the public service has stabilised

What are the other implications?

at about 1.32 million.

CHART 1: PERSISTENT DOWNGRADES OF GDP GROWTH FORECASTS

CHART 2: PLANS TO NARROW THE BUDGET DEFICITS PUSHED OUT… UNTIL NOW Projected budget balance as % of GDP

Projected real economic growth

4.0%

3.0%

2.0%

1.0%

0.0%

2011

2012

2013

2014

2015

2016

2013 Feb Budget

2014 Feb Budget

2015 Feb Budget

2016 Feb Budget

2016 Oct MTBPS

2017 Feb Budget

2017

2018

2019

Actual GDP Growth

Sources: National Treasury, StatsSA

-0.020

2013/14 2014/15 2015/16 2016/17 2017/18 2018/19 2019/20

-0.025 -0.030 -0.035 -0.040 -0.045 2014 Feb Budget

2015 Feb Budget

2016 Feb Budget

2016 Oct MTBPS

2017 Feb Budget

Actual Source: National Treasury

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BUDGET SPEECH 2017 CONSUMERS

is likely to be the first step towards maintaining current ratings as tough

It is important to remember that a “good” Budget for investors

tax measures in difficult economic conditions show determination.

and ratings agencies is not necessarily good for consumers, as it

Either way, a commitment to prudence is positive for bonds as it

ultimately involves SARS sticking its fingers deeper into their pockets.

caps the new supply of bonds and therefore supports prices. Fiscal

This includes an additional R12 billion in tax revenue gained from

consolidation tends to put downward pressure on inflation, making it more likely that the Reserve Bank will consider interest rate cuts,

not compensating for bracket creep (which affects the middle class

which is a further positive for domestic bonds.

most), a fuel levy increase that is expected to raise R3 billion, sin tax hikes, and an additional R4.4 billion from the new 45% top

EQUITIES

marginal tax bracket (the wealthy tend to spend a smaller proportion

The company tax rate was left unchanged, so there is no impact

of income and therefore the impact on overall consumer spending

on after-tax profits. Since the intention to increase tax revenue was

will be lower). The increase in Dividend Withholding Tax (DWT),

announced in October last year, it is likely to already be discounted in

which is expected to net R6.8 billion, will probably impact savings

the share prices of domestically focused companies. The increase in

more than spending.

DWT will reduce overall equity returns marginally, but global market

Welfare grants will be increased in line with inflation, so there will

developments are more likely to drive the JSE than the outcome of

be no impact on real spending.

the Budget Speech over time.

All this will erode households’ disposable income, but the additional

THE RAND

R28 billion tax burden represents only around 1% of the R2.6 trillion

The rand has appreciated sharply over the past year despite global

annual household consumption spending.

and local political uncertainty and the risk of ratings downgrades. The primary drivers of the rand are likely to remain commodity

Declining inflation should offset the negative impact on real disposable

prices, sentiment towards emerging markets and expectations for

income to some extent, which also means that the interest rate

US interest rate increases. The Budget is unlikely to change this, but

outlook is more favourable. Tighter fiscal policy could allow for

should Gordhan be removed from his post (unlikely, but the rumours

some loosening of monetary policy.

are persistent) it will add to short-term rand volatility.

BONDS A “good” Budget is necessary but not by itself sufficient to secure South Africa’s investment grade credit rating. It will also require political stability and faster economic growth. However, Wednesday’s Budget

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BUDGET SPEECH 2017: BUDGET TAX CHANGES

INCOME TAX RATES AND REBATES – 2017/2018 TAX YEAR

This means that a taxpayer earning less than these thresholds will pay no income tax in the 2017/2018 tax year. The impact of the proposed changes on individuals aged younger than 65 are:

TAX RATES – INDIVIDUALS AND SPECIAL TRUSTS Limited bracket creep relief has been provided for lower income earners, with an increase in personal income tax for higher income earners. A new 45% tax bracket has been created: Taxable income (R)

RATES OF TAX

R0 – R189 880

18% of each R1

R189 881 – R296 540

R34 178 + 26% of the amount above R189 880

R296 541 – R410 460

R61 910 + 31% of the amount above R296 540

R410 461 – R555 600

R97 225 + 36% of the amount above R410 460

R555 601 – R708 310

R149 475 + 39% of the amount above R555 600

R708 311 – R 1 500 000

R209 032 + 41% of the amount above R708 310

R1 500 001 and above

R533 625 + 45% of the amount above R1 500 000

Primary

R13 635

R13 500

Secondary (age 65 to below 75)

R7 479

R7 407

Tertiary (age 75 and older)

R2 493

R2 466

2016/2017 tax year

Below age 65

R75 750

R75 000

Age 65 to below 75

R117 300

R116 150

Age 75 and over

R131 150

R129 850

Tax change (R)

% change

150 000

13 500

13 365

-135

-1.0%

300 000

49 780

49 348

-432

-0.9%

500 000

116 460

115 824

-636

-0.5%

750 000

213 431

212 490

-941

-0.4%

1 000 000

315 931

314 990

-941

-0.3%

1 500 000

520 931

519 990

-941

-0.2%

2 000 000

725 931

744 990

19 059

2.6%

MAXIMUM EFFECTIVE RATES The effective rates for Capital Gains Tax (CGT) have changed (effective 1 March 2017) given the changes to the maximum income tax rate for individuals and trusts:

TAX THRESHOLDS The tax thresholds have increased. 2017/2018 tax year

Proposed 2017/18 rates (R)

CAPITAL GAINS TAX (CGT)

TAX REBATES The primary, secondary and tertiary rebates have increased. 2016/2017 tax year

2016/17 rates (R)

INCOME TAX RATES – COMPANIES For companies with a financial year ending between 1 April 2017 and 31 March 2018, income is taxed at a flat rate of 28%. This rate remains unchanged from the previous year of assessment.

With effect from 1 March 2017, all trusts, excluding special trusts, are taxed at a flat rate of 45%.

2017/2018 tax year

Taxable income (R)

2017/2018 tax year

2016/2017 tax year

2015/2016 tax year

Individuals, special trusts

18%

16.4%

13.7%

Companies

22.4% (unchanged)

22.4%

18.6%

Other trusts

36%

32.8%

27.3%

This will affect all investments held by individuals and trusts, other than Tax-Free Savings Accounts (TFSAs) and investments held by retirement funds and other tax-exempt entities. The annual exclusion for individuals remains at R40 000 (R300 000 in the year of death).

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BUDGET SPEECH 2017: BUDGET TAX CHANGES CONTINUED

INTEREST EXEMPTIONS – INDIVIDUALS

TAXATION OF SMALL BUSINESSES SMALL BUSINESS CORPORATIONS The tax rates for small business corporations (gross income under R20 million) for financial years ending on any date between 1 April 2017 and 31 March 2018 are:

The interest exemption threshold remains unchanged at R23 800 per annum for persons under the age 65, and at R34 500 per annum for persons aged 65 and older. These are not expected to change in the future following the introduction of Tax-Free Savings Accounts in 2015.

DIVIDEND WITHHOLDING TAX (DWT) Dividends received by individuals from South African companies are generally exempt from income tax, but dividends tax is withheld by the entities paying the dividends to the individuals. With effect from 22 February 2017, the local dividend withholding tax rate increases from 15% to 20%.1

R0 – R 75 750

0% of taxable income

R75 751 – R365 000

7% of taxable income above R75 750

R365 001 – R550 000

R20 248 + 21% of taxable income above R365 000

R550 001 and above

R59 098 + 28% of taxable income above R550 000

Dividends are tax-exempt if the beneficial owner of the dividend is a South African company, retirement fund or other exempt person. This also applies to dividends non-residents receive from real estate income. The exemption for foreign dividends received by South African residents will be adjusted in line with this new rate effective from 1 March 2017.

MICRO BUSINESSES

MEDICAL TAX CREDITS

R0 – R335 000

0% of taxable turnover

R335 001 – R500 000

1% of taxable turnover above R335 000

The tax rates for micro businesses (turnover not exceeding R1 million per year) are applicable for any year of assessment ending during the period of 12 months up to 28 February 2018, and remain unchanged from the previous year of assessment:

The medical aid tax credits for contributions to medical schemes increase with effect from 1 March 2017 to: • R303 per month for the taxpayer and first dependant (from R286), and

R500 001 – R750 000

R1 650 + 2% of taxable turnover above R500 000

• R204 per month for each additional dependant (from R192).

R750 001 and above

R6 650 + 3% of taxable turnover above R750 000

For taxpayers who are 65 or older, disabled or have disabled dependants, an additional tax credit will be given of an amount equal to the aggregate of:

TRANSFER DUTY

• 33.3% of the amount by which their contributions exceed three times their tax credit (for contributions), plus

Some relief has been provided in the affordable housing market through an increase in the threshold above which transfer duty is paid, from R750 000 to R900 000.

• 33.3% of their out-of-pocket expenses. The additional tax credit afforded to employees who are 65 and older with respect to their contributions to medical schemes may also be accounted for in the monthly PAYE calculations. This facility is also afforded to provisional taxpayers who are 65 years of age and older.

Property value (R)

Rate of tax (R)

R0 – R900 000

0% of property value

R900 001 – R1 250 000

3% of property value above R900 000

• The amount by which their contributions exceed four times their tax credit, plus

R1 250 001 – R1 750 000

R10 500 + 6% of property value above R1 250 000

• Their out-of-pocket expenses

R1 750 001 – R2 250 000

R40 500 + 8% of property value above R1 750 000

that exceeds 7.5% of their taxable income (excluding any retirement fund lump sum benefit, retirement fund lump sum withdrawal benefit and severance benefit).

R2 250 001 – R10 000 000

R80 500 + 11% of property value above R2 250 000

R10 000 001 and above

R933 000 + 13% of the property value above R10 000 000

For taxpayers younger than the age of 65, an additional tax credit will be given of an amount equal to 25% of the aggregate of:

Future adjustments to medical tax credits will be balanced with the funding requirements of National Health Insurance. 1

There is a difference in the effective date published in the “SARS Pocket Tax Guide” and the date provided in the National Treasury Budget Review document. The effective date above reflects the date in the National Treasury Budget Review document.

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BUDGET SPEECH 2017: BUDGET TAX CHANGES CONTINUED

TRAVELLING ALLOWANCE

TAX-FREE SAVINGS ACCOUNTS (TFSAs)

The use of a log book is compulsory to claim travel expenses for business purposes. The new table for the deduction of business travel where no records of actual costs are kept is as follows:

TFSAs were introduced to the South African investment market place for individuals in March 2015.

Value of the vehicle (incl VAT) (R)

Contributions are subject to an annual limit, which Government proposes

Fixed Cost (R p.a.)

Fixed cost (c/km)

Maintenance cost (c/km)

increasing from R30 000 to R33 000, and a lifetime limit which is to

0 – 85 000

28 492

91.2

32.9

Investment returns, growth and payouts in respect thereof are taxfree.

85 001 – 170 000

50 924

101.8

41.2

Old Mutual has been providing these investments since 1 March 2015.

170 001 – 255 000

73 427

110.6

45.4

255 001 – 340 000

93 267

118.9

49.6

340 001 – 425 000

113 179

127.2

58.2

425 001 – 510 000

134 035

146.0

68.4

510 001 – 595 000

154 879

150.9

84.9

Exceeding 595 000

154 879

150.9

84.9

remain unchanged at R500 000.

SPECIAL VOLUNTARY DISCLOSURE PROGRAMME (SVDP) The Minister introduced a Special Voluntary Disclosure Programme to encourage taxpayers to disclose their affairs and reveal any unauthorised assets and income abroad, before SARS obtains the information as part of the automatic exchange of information between tax authorities. The process for SVDP applications runs from 1 October 2016 to 31 August 2017. Any applications submitted after 31 August 2017 will not qualify for the special rules under the SVDP and the normal Voluntary Disclosure Programme rules will apply. TRUST LOAN ACCOUNTS

RETIREMENT FUND LUMP SUM BENEFIT TAX TABLES

Section 7C was introduced by the Taxation Laws Amendment Act of

Tax bands have remained unchanged compared to the previous Budget:

company to which the person is a connected person, to a trust to which

2016 and applies to instances where a loan, credit or an advance is made by a natural person or at the instance of such a person by a that person or company (or any person who is a connected person to that trust or company) is a connected person (i.e. where such company

WITHDRAWAL

or person, or anybody connected to them, is a beneficiary of such trust).

R0 – R25 000

0% of taxable income

R25 001 – R660 000

18% of taxable income above R25 000

Subject to certain exemptions, where a trust incurs no interest or interest

R660 001 – R990 000

R114 300 + 27% of taxable income above R660 000

equal to the difference between the interest incurred by the trust (if

R990 001 and above

R203 400 + 36% of taxable income above R990 000

of interest would be treated as a donation made to the trust (by such

at a rate lower than the official rate of interest (currently 8%), an amount any) and the interest that would have been incurred at the official rate connected person/company) on the last day of the tax year of the trust (i.e. 28/29 February) – thus potentially triggering donations tax. This section is effective from 1 March 2017 and applicable to loans, credit or advances made to trusts before, on and after 1 March 2017.

RETIREMENT, RETRENCHMENT, DEATH (INCLUDING SEVERANCE BENEFITS)

Some taxpayers have already attempted to avoid the provisions of this section by channelling these types of loans to companies owned by

R0 – R500 000

0% of taxable income

trusts. It is proposed to extend the scope of this section to counter these

R500 001 – R700 000

18% of taxable income above R500 000

avoidance schemes.

R700 001 – R1 050 000

R36 000 + 27% of taxable income above R700 000

R1 050 001 and above

R130 500 + 36% of taxable income above R1 050 000

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BUDGET SPEECH 2017: RETIREMENT REFORMS

PRESERVATION OF BENEFITS AFTER REACHING NORMAL RETIREMENT DATES

TAXATION OF CONTRIBUTIONS With effect from 1 March 2016:

In 2014, changes to the Income Tax Act allowed individuals to elect

• Contributions by employers to all retirement funds are fringe benefit

when to retire. This meant that the lump sum benefit accrued on the date

taxed in the hands of the employee.

on which the member elected to retire and not at normal retirement age.

• The full employer contribution is deductible by the employer.

Therefore, a member could elect to retire after reaching normal retirement

• The tax deductions for member contributions were simplified and

age if the rules of the fund provide for this.

improved with the introduction of a uniform 27.5% deduction of the

However, once a member elects to retire, the Act does not currently

higher of taxable income or remuneration, with a yearly deduction

allow for lump sum benefits to be transferred from one retirement fund

cap of R350 000.

to another. It is therefore proposed that transfers of retirement interests

The Taxation Laws Amendment Act of 2016 clarified that these

be allowed from one retirement fund to another, provided that the fund

earnings also include passive income and taxable capital gains

rules make provision for this.

for the purposes of the 27.5% component of the deduction. The

TAX-EXEMPT STATUS OF PRE-MARCH 1998 BUILDUP IN PUBLIC SECTOR FUNDS

deduction is, however, applied to taxable income before the addition of taxable capital gains for the purposes of the 27.5% component

The Income Tax Act makes provision for the transfer of the tax-free portion

of the deduction. There has been some confusion on how the

of lump sum benefits from a public sector fund to a pension fund. It is

R350 000 yearly cap will be applied, as currently, there is no provision

proposed that this tax-free treatment be extended to all subsequent transfers

for employers to smooth this over the whole tax year. It is proposed that

to another pension fund as well.2

this deduction be spread over the tax year.

REMOVING TIME LIMIT TO JOIN AN EMPLOYER UMBRELLA FUND

Contributions that exceed the allowable deduction are deemed to have been made in the following year and will be deductible subject to the

Existing employees who do not join a newly established employer

limits applicable in that year.

umbrella fund have 12 months within which to join the fund. To encourage

The Taxation Laws Amendment Act of 2016 confirmed that the roll-over

employees to contribute towards their retirement, it is proposed that this

only applies to excess contributions to retirement annuity funds and

12-month limit be removed allowing employees to join without time

pension funds prior to 1 March 2016. Contributions made to provident

restriction, provided that the rules of the fund make provision for this.

funds prior to 1 March 2016 will not form part of this concession and will not be deductible. Only contributions made to provident funds as of 1 March 2016 that exceed the limit will enjoy the roll-over relief. Any contributions that remain unapplied as deductions upon the member’s exit from the fund, may be applied against members’ retirement benefits on retirement, firstly against the lump sum and then against the annuity income.

PROVIDENT FUNDS' ANNUITISATION The proposal that compels certain provident fund and provident preservation fund members to purchase an annuity at retirement is subject to NEDLAC negotiation and consensus. If there is no consensus, this proposal will not be implemented and the continuation of deductions for member

2

contributions to provident funds will be reviewed.

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Even though the National Treasury Budget Review document only makes reference to pension funds, it is anticipated that this proposal would be extended to all relevant approved retirement funds.

BUDGET SPEECH 2017: BUDGET PROPOSALS

EMPLOYEES’ TAX AND REIMBURSED TRAVEL EXPENSES

• Simplifying and reducing the costs of retirement fund products;

To simplify the calculation of employees’ tax, it is proposed that employees

• Ensuring effective intermediation;

should only be taxed on the portion of the travel expenses reimbursed

• Introducing the concept of an umbrella fund into the Pension Funds

by an employer that exceeds the rate or distance fixed by the Minister.

Act so that these funds may be regulated more appropriately; and

SA RESIDENTS’ FOREIGN EMPLOYMENT INCOME TAX EXEMPTION

• National Treasury and the FSB to develop an appropriate unclaimed benefit policy.

Employment income earned by South African residents working in a foreign country for more than 183 days a year is exempt from tax subject to certain conditions. To avoid escaping taxation, it is proposed that this exemption only applies if the employment income is taxed in the foreign country.

SOCIAL SECURITY REFORM Government recently released a paper for comment setting out their plans for a comprehensive social security reform programme. A further paper is to be released by mid-year.

NATIONAL HEALTH INSURANCE (NHI) A follow-up to the 2011 paper was released in 2016. Government has undertaken to release a paper setting out further detail shortly. In the meantime, a limited NHI fund is to be set up catering for maternal, disability and elderly benefits as well as for the provision of spectacles. Various funding options are being considered including possible adjustments to the medical tax credits currently afforded to medical scheme members.

FINANCIAL SECTOR REFORMS The Twin Peaks reforms for prudential and market conduct regulations are on track with the recent tabling of the Financial Sector Regulations and Insurance Bill. In the short term, the Financial Services Board (FSB) is focusing on certain specific market conduct concerns such as the demarcation of medical schemes, emolument attachments on state employees and consumer credit insurance abuses.

OTHER RETIREMENT SECTOR REFORMS Some further reforms in the pipeline are: • Auto enrolment of employees into retirement funds; • Clarifying trustee duties including investment and preservation defaults and annuity strategies for retirees – a more principles-based version of the “default regulations” has been released for comment; • National Treasury to consult with industry on developing low-cost, value-for-money annuities for lower income employees;

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BUDGET SPEECH 2017: THE BOTTOM LINE

Minister Gordhan found himself in a similar position to last year and again

INCOME TAX CALCULATOR

produced a budget which attempts to address various divergent agendas

If you would like to calculate your monthly income tax and compare it

and economic realities. There is specific focus on the transformation of

to last year, you may wish to use Old Mutual’s Income Tax Calculator.

the South African economic landscape - both the nature of the economy

You will be able to see the benefits of retirement reform where your

and who owns and controls it.

income tax is concerned.

The funding of these agendas is challenging in the economic environment

This calculator takes your monthly income, retirement contributions,

that South Africa currently faces.

medical expense amounts and your employer’s contribution to risk benefits and retirement funds into account and can be found on

It is now more clear than ever that taxpayers need to invest their hard-

the following site: https://www.oldmutual.co.za/markets/south-

earned money in a tax-efficient way. The tax-efficient benefits of retirement

african-budget/income-tax-calculator.

funds and TFSAs should not be overlooked, especially in light of the more favourable tax deduction regime for retirement funds and the increase in the limit for TFSAs. Minister Gordhan indicated that the expected growth rate for 2017 was simply too low to meet our national development targets. Government has undertaken to facilitate a more investor-friendly environment while pursuing a radical transformation of the South African economic landscape. The Minister called on all South Africans to assist in meeting these challenges and invoked the words of the poet SEK Mqhayi when referring to the soldiers who lost their lives on the SS Mendi a century ago: "Somebody has to serve, so that others can live."

IMPORTANT INFORMATION Old Mutual Wealth (OMW) is an elite service offering brought to you by several licenced Financial Services Providers in the Old Mutual Group (“the Old Mutual Group”). This document is for information purposes only and does not constitute financial advice in any way or form. It is important to consult a financial planner to receive financial advice before acting on any information contained herein. OMW, the Old Mutual Group and its directors, officers and employees shall not be responsible and disclaim all liability for any loss, damage (whether direct, indirect, special or consequential) and/or expense of any nature whatsoever, which may be suffered as a result of, or which may be attributable directly or indirectly to, the use of, or reliance upon, any information contained on the Old Mutual Wealth website. The information is compiled in good faith and based on sources believed to be reliable, accurate and up to date, but no representations are made as to the accuracy, completeness or suitability of the information and no responsibility is accepted by OMW and/or the Old Mutual Group for any damages which may flow from the use of any information. Until the proposals have formally been promulgated, they should only be viewed as proposals.

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