Yes, potentially. South African income-tax law does not make “cash” the only form in which taxable income can arise. In Lategan v Commissioner for Inland Revenue 1926 CPD 203, the court considered the meaning of “amount” in the definition of gross income and held that it was wide enough to include more than money – it could include the value of property and rights received or accrued. The principle is important because a taxpayer cannot necessarily avoid tax merely because what they received was something other than cash.
The principle remains relevant to modern transactions. A farmer who receives goods in exchange for produce may have a barter transaction, with the value of what is received being relevant to the tax consequences. The same concept now reaches the digital economy: SARS expressly states that where goods or services are exchanged for crypto assets, the transaction is regarded as barter and the normal barter rules apply. Whether the resulting amount is taxed as ordinary income or dealt with under the capital gains regime will depend on the nature of the taxpayer’s activity and the particular transaction.
So, whether the payment is a load of mealies, another service, or Bitcoin, the important question is not simply “Did money change hands?” The better question is: “What did I receive, what was its value, and did it constitute an amount received or accrued in terms of the Income Tax Act?” In 2026, that question has become even more relevant as SARS implements the Crypto-Asset Reporting Framework, under which crypto-asset service providers report specified transaction information to SARS.