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...
by Pieter van der Zwan | Jul 1, 2018 | Corporate and business tax, Individuals and wealth planning
The venture capital company (VCC) tax incentive was introduced in 2008 to assist small and medium entities in raising equity funding. An investor in a VCC can deduct the amount of the investment from his taxable income, despite this being a capital investment. The VCC...
by Pieter van der Zwan | Jun 10, 2018 | General tax matters
The Tax Administration Act (TAA) makes provision for prescription of tax assessments. This provides taxpayers with finality in relation to assessments after a period of time. The SCA considered in CSARS v Char-Trade whether an assessment had prescribed by the time...
by Pieter van der Zwan | May 11, 2018 | General tax matters
The previous article on the topic of understatement penalties (USP) concluded that taxpayers need to carefully consider the quality of and critically assess the soundness of advice obtained if they wish to rely on it as a basis to have reasonable grounds for a tax...
