The general anti-avoidance rules (GAAR) in sections 80A to 80L of the Income Tax Act 58 of 1962 (the Income Tax Act) have...
The ABSA case: “Party” and “Tax Benefit” under the GAAR
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General tax matters
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...
Be careful of the GAAR
The number of cases before South African courts involving the general anti-avoidance rules (the GAAR) have increased noticeably...
Changing course during a tax dispute
Taxpayers often refine their grounds and arguments as a tax dispute progresses. The Western Cape Division of the High Court...
Trusts: Conduit-pipe tax rules
The appellate division established the conduit-pipe principle in 1938 in Armstrong v CIR and confirmed it in subsequent cases....
Relief for SA tax residents who incur foreign taxes
South Africa has a residence-based income tax system. This means South African tax residents are subject to income tax on all...