All Articles
Changes to venture capital company tax regime
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...
Valuation of trading stock for tax using IFRS as a basis
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...
Respublica case: Characterisation of the supply of property
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...
Kangra Group case: Deductibility of damages settlement payment
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...
The tax effect of terms of financing instruments
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...
SARS views on venture capital company rules
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...
Trust our expert knowledge and experience to reduce your uncertainty and solve your complex tax problems.
Need Advice?
We regularly advise and assist clients with South African tax matters. Do you need an opinion on the South African tax implications of a transaction or arrangement? Do you require assistance to resolve a tax dispute?