by Pieter van der Zwan | Jan 13, 2019 | Corporate and business tax, Individuals and wealth planning
The South African National Treasury introduced the venture capital company (VCC) regime in section 12J of the Income Tax Act in 2008 as an incentive for investors to make equity funding available to small and upcoming businesses housed in qualifying companies. Despite...
by Pieter van der Zwan | Nov 7, 2018 | Corporate and business tax, General tax matters
Income tax returns are often prepared using financial statements as a starting point and making some adjustments to reflect the differences between accounting profits and taxable income. In C:SARS v Volkswagen SA (Pty) Ltd the SCA considered whether a taxpayer could...
by Pieter van der Zwan | Oct 18, 2018 | Value Added Tax
When it comes to property rental transactions a number of permutations exist from a VAT perspective. In brief, the agreement can give rise to a supply of residential accommodation (which is exempt), a supply of commercial accommodation (which is not fully subject to...
by Pieter van der Zwan | Oct 10, 2018 | Corporate and business tax, General tax matters
The tax implications of arrangements involving claims for damages are often complex, whether viewed from the perspective of the payor or recipient. The case of Kangra Group (Pty) Ltd v C:SARS (Kangra case), which was recently heard by the Western Cape division of the...
by Pieter van der Zwan | Aug 6, 2018 | Corporate and business tax, General tax matters
The case of Crookes Brothers Limited v C:SARS was widely commented as a rare case that deals with the South African transfer pricing provisions. The court considered the application of an exemption from the transfer pricing rules for loans with equity-like features...
