A/Prof Afton Titus

A/Prof. Afton Titus

​Contact Details:

021 650 2617

Room 5.09, Kramer Law Building, Middle campus. UCT.


Senior Lecturer


Afton Titus graduated from UCT with Bachelor of Commerce and Bachelor of Laws degrees. She thereafter completed her articles, and was admitted to the High Court as an attorney, notary and conveyancer. She practiced as a tax attorney for a further two years while completing her Master of Commerce degree in Taxation from UCT in 2010. She joined the Commercial Law Department as a lecturer in 2011. Afton completed her PhD with the University of Amsterdam in 2020. - See more at:


CML5661F General Tax Law Provisions (Masters’ Class)

CML4661F General Tax Law Provisions (Postgraduate Diploma Class)

CML4506F Tax Law A (LLB Class)

Research Interests

Tax implications of regionalism; fiscal federalism; international tax in a developing country context; tax implications of sustainable development goals-building.


Peer Reviewed Publications

‘Pienaar Bros (Pty) Ltd v CSARS, Retroactive Legislation and the Rule of Law: Has South Africa just taken a step back in its constitutional democracy?’

2019 South African Law Journal (forthcoming)

‘The Relationship between Tax Incentives and Human Rights Obligations in the Drive to Attract Foreign Direct Investment: Are African Developing Countries Getting it Right?’

Acta Juridica 2019 (forthcoming) (with Tracy Gutuza)

‘Designing a General Anti-Avoidance Rule for the East African Community – A Comparative Analysis’ (2019) 11(2) World Tax Journal 261 – 301.

‘How Can the East African Community Guard Against Base Erosion and Profit Shifting While Working Towards Deeper Integration?’ (2017) 9(4) World Tax Journal 565 – 597.

‘May an investment in interest-bearing securities constitute a trade for the purpose of the Income Tax Act?’ (2016) 133(3) South African Law Journal 504 – 521.

‘A Review of the Taxation of Partnerships in South Africa over the last 100 years’ in Income Tax in South Africa: The First 100 Years (1914 - 2014), J. Hattingh, J. Roeleveld, and C. West, eds. (South Africa, Juta, 2016) 132 - 143.

‘The Role of the Limited Partner Deeming Provision in the Income Tax Act: Does section 24H(2) Achieve its Intended Purpose?’ (2014) 35(3) Obiter 658 – 671.

‘The Different Permutations of CSARS v Brummeria: Was it something other than an interest-free loan?’ (2012) 129(2) South African Law Journal 236 – 247.

Other publications

Law of South Africa: ‘Film and Television Production and Production Exploitation Law’ vol. 18, Third Edition, 2018 (with Lee-Ann Tong and Salona Lutchman).

Fiscal Federalism and the EAC: The Way Forward’1(1) International Law Journal On Trade, Business and Economics 2014, 1.

Works Submitted for Review (2019)

‘The Decolonization Movement in South Africa: Is Tax Law Decolonised?’ (with Tracy Gutuza) 

Contribution to book entitled: ‘The Decolonisation of Law in South Africa’ (Juta publishers)

Date of Submission: January 2019.

‘How Can the Formation of a Federation Assist the East African Community in Guarding Against Base Erosion and Profit Shifting?’

Submitted to: Journal of African Law

Date of submission: March 2019.

‘The Promise of Non-Arm’s Length Practices – Is the Destination-Based Cash Flow Tax and Unitary Taxation the Panacea of which Developing Countries are in Search?’

Contribution to book entitled: ‘The Link between Tax, Development, Law and the Sustainable Development Goals in the Global South’ (Springer).

Date of Submission: September 2019.

‘The Common Consolidated Corporate Tax Base and the East African Community’s Envisaged Federation – A Viable Legal Transplant?’

Submitted to: Intertax (Special Edition)

Date of Submission: November 2019.

‘Domestic Revenue Mobilization through Corporate Income Tax in a Developing Country Context’

Submitted to: Dalhousie Law Journal

Date of Submission: December 2019.