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Tax on cryptocurrency transactions
Cryptocurrencies present lucrative trading as their short-term values fluctuate wildly. They may however also prove to be good longer term investments if the value ultimately grows substantially when held over a longer period of time. Over the past few months,...
Section 24C: The ‘contractual sameness’ requirement
Taxpayers may deduct an allowance for expenditure not yet incurred in the circumstances set out in section 24C of the Income Tax Act. This provision has been the subject of two disputes that proceeded to the Constitutional Court (‘CC’), which in itself is...
Exposure to penalties while in an assessed loss position
Introduction Taxpayers who find themselves in a loss-making position often intuitively assume that as long as they are not liable to pay tax due to the fact that they have an assessed loss, they would not be exposed to understatement penalties (‘USPs’). This...
Budget 2021: Tax proposals
The National Treasury published the Budget Review 2021 on 24 February 2021. This document contains the announcements of tax rates and scales, but also proposals for various tax amendments of a more technical nature that the National Treasury intends to make as part...
The 2020 tax amendments
The National Treasury recently published a number of bills that contain the amendments to the tax laws for the 2020 legislative cycle. This article reviews a selection of amendments that are likely to be of broad relevance to taxpayers and advisors. It is not intended...
The mechanics of asset-for-share transactions
Asset-for-share transactions qualify for relief under the corporate rule in section 42 of the Income Tax Act (‘the ITA’). In the course of advising on these transactions or reviewing transactions proposed to taxpayers, I realised that taxpayers are often not aware of...
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