Section 12J Funds

Who should start a Section 12J VCC?

South African taxpayers who are looking to invest into South African companies or projects should consider forming a Section 12J Venture Capital Company (VCC) given the significant tax incentive they would receive.

Examples of some of the sectors/areas within which VCCs have been implemented successfully include:

  • renewable energy
    • commercial and residential roof top solar solutions
    • large PV projects
    • wind energy projects
  • franchises
  • mining – junior mining
  • hospitality
    • student residence developments
    • hotel developments
  • private equity firms & family offices
  • movable property leasing

VCCs can invest across most sectors except:

  • property, unless in the hospitality sector as defined in the Income Tax Act (this definition generally includes hotels, serviced apartments and student residence)
  • any trade carried on in the financial services sector (i.e banking, insurance etc)
  • any trade carried on in respect of financial or advisory services
  • gambling, liquor, tobacco, arms or ammunition
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