The South African government approved a tax incentive for Air Liquide (Pty) Ltd as part of the Tax Allowance Program.



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Department of Trade and Industry. Section 12I Tax Allowance Incentive (12I TAI). Available at:

Government Gazette. The Republic of South Africa. Volume 592 No. 38032 of 3 October 2014. Department of Trade and Industry. Notice 756 of 2014. Available at:

Inception date: 03 Oct 2014 | Removal date: open ended

Tax or social insurance relief

On 3 October 2014, the Department of Trade and Industry (DTI) of South Africa issued Notice 756 announcing the approval of an application made by Air Liquide (Pty) Ltd for the 12I Tax Allowance Programme. As a result, the investment allowance granted to the gas manufacturer and provider which is deductible from taxable income is ZAR 239.8 million (USD 21 million), and the training allowance is circa ZAR 720,000 (USD 63,000).

The DTI has stated that from the company's total investments estimated at ZAR 320.4 million (USD 28.2 million), the manufacturing qualifying assets accounted for ZAR 319.7 million (USD 28.1 million). Due to the specific characteristics of the project, the DTI classified this investment as a Greenfield project.

The purpose of the investment is to finance the Coega Air Separation Unit, a project to manufacture gaseous Oxygen and Nitrogen as well as Liquid Oxygen and Argon.

Section 12I Tax Allowance Incentive
The 12I Tax Incentive seeks to promote Greenfield and Brownfield investments with the objective to boost the productivity of the South African manufacturing sector and increase the productivity of the human capital.

The minimum investment required in qualifying assets is ZAR 50 million for a greenfield project (projects that use only new and unused manufacturing assets) and an additional investment of ZAR 30 million for a brownfield project (expansions or upgrades of existing industrial complexes). 

The total investment allowance range between 35% and 55% (or ZAR 350 million and ZAR 900 million) depending on the type of the investment, the status classification, and the localization.