In her thesis, A Framework for Wealth Transfer Taxation in South Africa, the promovenda examines the current South African wealth transfer tax regimes, comprising of estate duty levied in terms of the Estate Duty Act of 1955 and donations tax levied in terms of Part V of the Income Tax Act of 1968, which are both levied on the transferor. After having come to the conclusion that wealth transfer taxation is justifiable for the South African tax system (notwithstanding the fact that capital gains tax is levied on a realisation-basis), the promovenda explores two key issues.

The first issue relates to the lack of integration that exists between the taxation of inter vivos transfers (under the donations tax regime) and the taxation of transfers on death (under the estate duty regime). After having compared the systems in the United Kingdom, the Netherlands and Ireland, the promovenda recommends a number of measures to improve integration under the current South African regimes, but suggests that, ideally, the Estate Duty Act and Part V of the Income Tax Act should be replaced by a single integrated statute.

The second issue deals with the transferor-based /recipient-based tax debate. After having shown that a recipient-based wealth transfer tax offers more appropriate solutions to some of the problem areas common to wealth transfer taxation in general (such as the accommodation of third-party life insurance benefits, limited interests and a special regime for discretionary trusts), the promovenda concludes that the current regimes should be replaced by a recipient-based wealth transfer tax system, which may even be accommodated as a separate schedule to the existing Income Tax Act in much the same way as capital gains tax.