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The importance of a thorough objection
The first step for an aggrieved taxpayer to dispute a tax assessment is generally to lodge an objection in terms of section 104 of the Tax Administration Act (the TAA). In this article, I consider The Commissioner for the South African Revenue Service v Airports...
Tax treatment of costs to raise funding
There are many costs to raise funding for a business, whether debt or equity capital. These include raising fees, initiation fees, facility fees and charges relating to structuring the transaction, to mention a few. In this article, I consider a recent case that dealt...
VAT proposals for 2022
VAT vendors can expect a number of amendments that affect specific classes of vendors in 2023. The National Treasury published the draft Taxation Laws Amendment Bill (‘TLAB’) for comment on 29 July 2022. It contains a number of proposals for amendments to the Value...
Corporate tax proposals for 2022
What awaits corporate taxpayers in the 2023? The National Treasury published the draft proposals for tax amendments for the 2022 legislative cycle on 29 July 2022. These give taxpayers an indication of the changes to expect at the end of 2022 (click here for the...
C:SARS v Capitec: A case of VAT equilibrium?
In Commissioner for the South African Revenue Service v Capitec Bank Limited (94/2021) [2022] ZASCA 97 (21 June 2022) the Supreme Court of Appeal ruled that Capitec Bank Limited (‘Capitec’) could not deduct input tax in respect of loan cover payouts to borrowers. This...
Management fees: Is there a tax risk?
Managers who advise and manage the affairs of others, for example, their investments or businesses, often charge management fees for those services. This is not unusual or out of the ordinary. In a tax context, certain arrangements that are labelled as management...
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