The South African Revenue Service has published a judgment from the Constitutional Court delivered on 22 April 2026 in Absa Bank Ltd and Another v CSARS (CCT 72/24). The case concerned whether ABSA Bank Limited (ABSA) could be held liable for tax under the General Anti-Avoidance Rules (GAAR) regarding a complex ZAR 1.9 billion preference share investment structure designed by the Macquarie Group. ABSA invested in preference shares through various intermediaries. The funds were used in a back…