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A contribution to Ubuntu Gale can support a claim under this instrument today, on the ordinary conditions listed.
1 instrumentSouth African instruments
Eleven instruments a South African corporate funder may be able to use, each with the statute, the benefit, the conditions, the documentation, and an explicit statement of whether Ubuntu Gale can support a claim under it today.
Indicative only — not tax, legal or financial advice. Every figure on this page is a general statement of published law and codes, not an assessment of your circumstances. Tax and B-BBEE outcomes depend on your entity type, financial position, verification agency and the facts of the contribution. Confirm any figure with your own tax adviser, auditor and B-BBEE verification professional before you rely on it. Ubuntu Gale does not issue s18A receipts and does not hold public benefit organisation approval.
Last reviewed 2026-07-29
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A contribution to Ubuntu Gale can support a claim under this instrument today, on the ordinary conditions listed.
1 instrumentThe instrument can apply, but the outcome depends on facts we cannot assess for you — your entity type, targets, scorecard and verification.
4 instrumentsIncluded so the picture is complete. It is not a benefit Ubuntu Gale can deliver or claim on your behalf.
3 instrumentsUbuntu Gale does not currently hold the approval or registration this instrument requires. Do not plan a contribution on the basis of it.
3 instrumentsA contribution to Ubuntu Gale can support a claim under this instrument today, on the ordinary conditions listed.
Income Tax Act 58 of 1962, s11(a) read with s11(d) and s23(g)
Allows a deduction for expenditure and losses actually incurred in the production of income, not of a capital nature, in carrying on a trade. Skills development, enterprise and supplier development and corporate social investment spend is frequently deductible on this basis where it is incurred for business purposes.
Who qualifies. Any taxpayer carrying on a trade. The test is the purpose of the expenditure and its connection to the income-earning operations, not the identity of the recipient.
Where a contribution is made for a business purpose — securing a skills pipeline, meeting a scorecard obligation, developing suppliers, protecting a social licence to operate — it is generally deductible in full in the year incurred, without the 10% ceiling that applies to s18A donations. This is the route most Ubuntu Gale contributions realistically take today.
A contribution to Ubuntu Gale can be structured as deductible business expenditure today, and Ubuntu Gale can supply the funding agreement, invoice and delivery reporting that supports it. Whether your particular contribution meets the s11(a) test is a question for your tax adviser on your facts — we make no representation about your deduction.
The instrument can apply, but the outcome depends on facts we cannot assess for you — your entity type, targets, scorecard and verification.
Income Tax Act 58 of 1962, s56(1)(h)
Exempts a donation from donations tax where the donee is a public benefit organisation approved under s30, an institution exempt under s10(1)(cA)(i), or certain other listed bodies.
Who qualifies. Any donor making a donation to an approved recipient. Without the exemption, donations tax is levied on the donor at 20% of the value donated, rising to 25% on the cumulative value above R30 million.
This is a separate saving from the s18A deduction and is often overlooked. A donation to an unapproved body is not merely non-deductible — it can attract donations tax payable by the donor.
This exemption follows PBO approval, which Ubuntu Gale does not yet hold. Until it does, a donation to Ubuntu Gale falls to be considered under the ordinary donations tax rules and your adviser should confirm the treatment — including whether the payment is in fact a donation or deductible business expenditure under s11(a)/(d).
B-BBEE Amended Codes of Good Practice, Code Series 300
Scores a measured entity on skills development expenditure on black people as a percentage of its leviable amount, on the number of black people in learnerships, apprenticeships and internships, and on the absorption of unemployed learners into employment.
Who qualifies. Generic enterprises and Qualifying Small Enterprises being measured under the Amended Codes. Skills Development is a priority element for Generic enterprises, so a sub-minimum failure triggers discounting of the overall level.
For a Generic enterprise the skills development spend target is 6% of the leviable amount, split as 3.5% on core skills development for black people (6 points) and 2.5% on bursaries for black students at Higher Education Institutions (4 points), with spend weighted to Economically Active Population demographics. A QSE target is 3%. A further 4 points are available where black unemployed learners on category 18.1 or 18.2 programmes equal 2.5% of headcount, and 5 bonus points where all of those unemployed learners are absorbed into employment at the end of the programme.
Ubuntu Gale programmes are structured to produce the participation, attendance and outcome evidence a verification agency asks for, and we will supply it. But Ubuntu Gale is not accredited by SAQA, the QCTO or any SETA, so our programmes are not learnerships and cannot be claimed as category 18.1 or 18.2 learning programmes. Which Learning Programme Matrix category, if any, your verification agency accepts is their determination and not ours — establish that with them before you commit spend on this basis.
B-BBEE Amended Codes of Good Practice, Code Series 400
Scores preferential procurement, supplier development and enterprise development contributions that grow black-owned suppliers and black-owned enterprises within and beyond the measured entity's supply chain.
Who qualifies. Generic enterprises and QSEs. Enterprise and Supplier Development is a priority element for Generic enterprises.
Enterprise Development contributions carry a target of 1% of net profit after tax and Supplier Development contributions a target of 2% of NPAT, alongside the preferential procurement sub-elements. The element carries 42 weighting points before bonus points.
Where an Ubuntu Gale programme develops named black-owned small businesses, the recognisable contribution is generally the support delivered to those beneficiary enterprises, not the payment to Ubuntu Gale itself. That distinction is the one verification agencies test hardest. We can structure a restricted contribution around identified beneficiary enterprises and report at beneficiary level; whether your agency recognises it, and at what benefit factor, is their call.
B-BBEE Amended Codes of Good Practice, Code Series 500
Scores contributions that facilitate sustainable access to the economy for black people — including community development, education access, health and welfare initiatives — measured as a percentage of net profit after tax.
Who qualifies. Generic enterprises and QSEs measured under the Amended Codes.
The annual value of Socio-Economic Development contributions as a percentage of net profit after tax has a target of 1%, carrying 5 weighting points on the Generic scorecard. At least 75% of the beneficiaries must be black.
Ubuntu Gale's participant base and reporting are built to evidence beneficiary demographics, which is the part of a SED claim most commonly rejected on verification. Recognition still depends on your verification agency accepting the contribution and the beneficiary evidence. We will not assert points on your scorecard.
Included so the picture is complete. It is not a benefit Ubuntu Gale can deliver or claim on your behalf.
Skills Development Levies Act 9 of 1999
Levies 1% of an employer's total payroll, collected by SARS and distributed to the SETAs and the National Skills Fund. A portion returns to the employer as a mandatory grant, with further discretionary grants available for approved programmes.
Who qualifies. Employers with an annual payroll above the registration threshold. Registration is with SARS, and the levy is paid monthly on the EMP201.
An employer that submits a compliant Workplace Skills Plan and Annual Training Report by the SETA deadline can recover a mandatory grant of 20% of the levy paid. Discretionary grants for learnerships, bursaries and priority skills are awarded separately at the SETA's discretion. Employers routinely forfeit the mandatory grant simply by missing the submission date.
This sits on the employer's side of the relationship. Ubuntu Gale cannot recover a mandatory or discretionary grant for you, and our programmes are not SETA-registered learnerships. Included because the levy is where most corporate skills budgets originate, and because employers frequently forfeit the 20% mandatory grant through a missed deadline rather than a lack of training.
Employment Tax Incentive Act 26 of 2013
Reduces the employees' tax an employer pays over to SARS in respect of qualifying employees aged 18 to 29, for up to 24 months per employee, without reducing the employee's own wage.
Who qualifies. A private employer registered for employees' tax and tax compliant, employing a qualifying employee aged 18 to 29 who was employed on or after 1 October 2013, earns within the prescribed remuneration bands and is not a connected person to the employer.
The incentive is calculated per qualifying employee per month on a sliding scale linked to monthly remuneration, at a higher rate in the first 12 months and a reduced rate in the second 12. It becomes relevant to a funder at the point where programme graduates are absorbed into employment — which is also where the B-BBEE absorption bonus points sit.
Relevant only where your organisation employs a person, including an Ubuntu Gale programme graduate. Ubuntu Gale makes no claim under it and does not guarantee employment for any participant.
Value-Added Tax Act 89 of 1991
Determines whether a payment to a non-profit is consideration for a taxable supply, and therefore whether VAT must be accounted for and whether an input tax deduction is available to the payer.
Who qualifies. Any vendor making or receiving a grant, donation or sponsorship payment.
A genuine unconditional donation is not consideration for a supply, so no VAT arises and there is no input tax to deduct. A conditional grant — where the payer receives identified goods, services, naming rights, advertising or reporting deliverables in return — may constitute consideration for a deemed or actual supply, with VAT consequences on both sides. How the funding agreement is drafted, not what it is called, decides the treatment.
Included so that a funder's finance team can characterise a contribution correctly before signature rather than after. Ubuntu Gale will draft a contribution agreement that states plainly what is and is not provided in return; your VAT treatment remains a matter for your own advisers.
Ubuntu Gale does not currently hold the approval or registration this instrument requires. Do not plan a contribution on the basis of it.
Income Tax Act 58 of 1962, s18A
Allows a taxpayer to deduct bona fide donations of cash or property in kind made to an organisation approved by SARS to issue s18A receipts, provided the donation funds a public benefit activity listed in Part II of the Ninth Schedule.
Who qualifies. Any South African taxpayer — individual, company or trust — holding a valid s18A receipt from an approved organisation.
The deduction is limited to 10% of taxable income calculated before the s18A deduction itself. Any donation above the limit is carried forward and treated as a donation made in the following year of assessment, so nothing is lost — it is deferred.
Ubuntu Gale has NOT been granted s18A approval and cannot issue a s18A receipt. A donation made to Ubuntu Gale today does not support a s18A deduction. Any proposal that assumes one is incorrect. The expanded receipt particulars listed above are enforced from 1 March 2026, so a receipt issued without them will not support a claim even where approval exists.
Income Tax Act 58 of 1962, s10(1)(cN) read with s30
Exempts the receipts and accruals of an approved public benefit organisation from income tax, to the extent that they arise from public benefit activities listed in the Ninth Schedule and from permitted trading within the prescribed limits.
Who qualifies. A non-profit company, trust or association of persons approved by the SARS Tax Exemption Unit under s30, carrying on one or more Ninth Schedule public benefit activities in a non-profit manner with an altruistic or philanthropic intent.
The exemption applies to the organisation, not the funder. It matters to a corporate funder because it is the gateway approval: donations tax exemption under s56(1)(h) and s18A receipting both follow from it, and most funder due-diligence checklists ask for the approval letter and PBO number.
Ubuntu Gale is a registered non-profit company (UBUNTU GALE NPC, CIPC reg. 2026/299242/08) but does not hold PBO approval under s30. Non-profit incorporation and PBO approval are separate things and are commonly conflated; we will not describe ourselves as a PBO until the approval letter exists.
Income Tax Act 58 of 1962, s12H
Gives an employer an additional deduction for each registered learnership or apprenticeship agreement: an annual allowance for each year the agreement is in force, and a completion allowance in the year the learner completes.
Who qualifies. An employer that is a party to a learnership agreement or apprenticeship registered with a SETA in terms of the Skills Development Act. The learner must be employed by that employer under the registered agreement.
For a learner holding an NQF level 1 to 6 qualification, the annual allowance is R40,000 and the completion allowance a further R40,000. For NQF levels 7 to 10 both figures are R20,000. Where the learner has a disability the figures are R60,000 and R50,000 respectively. Both the annual and the completion allowance may be claimed in the year the learnership completes, so a completing NQF 1–6 learner can carry R80,000 of allowance in a single year.
Applies to learnership agreements entered into before 1 April 2027.
CRITICAL — s12H is NOT available for funding an Ubuntu Gale programme. The allowance attaches to a learnership agreement registered with a SETA between an employer and a learner. Ubuntu Gale programmes are not SETA-registered learnerships, Ubuntu Gale is not an accredited training provider, and a contribution to Ubuntu Gale creates no registered agreement. Any proposal, deck or estimate that shows s12H relief against an Ubuntu Gale contribution is wrong, and we will say so.
Benefit estimator
Enter your own figures to see the published B-BBEE targets they imply, and how an intended contribution maps against them. Every output is labelled with whether Ubuntu Gale can currently support a claim under that instrument.
Runs entirely in your browser. Nothing you type here is sent to Ubuntu Gale, saved or measured.
Percentages are the published Amended Codes targets. Whether a particular contribution is recognised, and at what benefit factor, is determined by your verification agency and not by Ubuntu Gale.
Code 400. Recognisable where the beneficiary is a 51% black-owned EME or QSE that is not already a supplier to you, and where your verification agency accepts the contribution at the applicable benefit factor.
Code 400. Applies to beneficiaries that are existing suppliers to your business. The distinction between Enterprise and Supplier Development is the one most often corrected on verification.
Code 500, worth 5 points at target. At least 75% of beneficiaries must be black. Ubuntu Gale reports beneficiary demographics; recognition remains your verification agency's determination.
Calculated on the leviable amount you entered, at the target for your measurement category.
Code 300. Skills Development is a priority element for Generic enterprises, so missing the 40% sub-minimum discounts your overall level by one.
Spend on black people across the Learning Programme Matrix, weighted to Economically Active Population demographics.
Bursaries for black students at Higher Education Institutions. Ubuntu Gale is not a Higher Education Institution, so this sub-target cannot be met through an Ubuntu Gale contribution.
Shown so the picture is complete, and struck through so no figure below can be mistaken for one you can claim on an Ubuntu Gale contribution.
Shown for completeness only. Ubuntu Gale does NOT hold s18A approval and cannot issue a s18A receipt, so a contribution to Ubuntu Gale supports no deduction under this heading. Ask your adviser about s11(a) instead, which is the route that is available today.
Annual allowance plus completion allowance, both claimable in the year of completion. It requires a learnership or apprenticeship agreement registered with a SETA between an employer and a learner. Ubuntu Gale programmes are not SETA-registered learnerships, so a contribution to Ubuntu Gale creates no s12H claim. The allowance also applies only to agreements entered into before 1 April 2027.
Annual allowance plus completion allowance, both claimable in the year of completion. It requires a learnership or apprenticeship agreement registered with a SETA between an employer and a learner. Ubuntu Gale programmes are not SETA-registered learnerships, so a contribution to Ubuntu Gale creates no s12H claim. The allowance also applies only to agreements entered into before 1 April 2027.
Annual allowance plus completion allowance, both claimable in the year of completion. It requires a learnership or apprenticeship agreement registered with a SETA between an employer and a learner. Ubuntu Gale programmes are not SETA-registered learnerships, so a contribution to Ubuntu Gale creates no s12H claim. The allowance also applies only to agreements entered into before 1 April 2027.
Indicative only — not tax, legal or financial advice. Every figure on this page is a general statement of published law and codes, not an assessment of your circumstances. Tax and B-BBEE outcomes depend on your entity type, financial position, verification agency and the facts of the contribution. Confirm any figure with your own tax adviser, auditor and B-BBEE verification professional before you rely on it. Ubuntu Gale does not issue s18A receipts and does not hold public benefit organisation approval.
Last reviewed 2026-07-29
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The route that works is usually not the one a funder arrives with. Tell us what you are trying to achieve and we will tell you what is genuinely available — including when the answer is that we are not the right recipient.