Section 42 of the Income Tax Act often features in restructuring discussions or proposals. When considering transactions or...
What is section 42 not?
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Corporate and business tax
What is section 42?
Taxpayers and their advisors employ section 42 of the Income Tax Act in various types of transactions. When encountering this...
To charge interest or not?
The question often arises whether the tax law obliges certain lenders to charge interest on loans to connected parties. This...
The timing of tax deductions matters
One often encounters arguments that the year in which something is taxed or deducted does not really matter: as long as SARS...
The ABSA case: “Party” and “Tax Benefit” under the GAAR
The general anti-avoidance rules (GAAR) in sections 80A to 80L of the Income Tax Act 58 of 1962 (the Income Tax Act) have...
Income tax considerations for homeowners’ associations
Section 10(1)(e) of the Income Tax Act 58 of 1962 (the ITA) exempts levy income received by bodies corporate, share block...