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The ABSA case: “Party” and “Tax Benefit” under the GAAR

The ABSA case: “Party” and “Tax Benefit” under the GAAR

by Pieter van der Zwan | May 20, 2026 | Corporate and business tax, General tax matters, Uncategorized

The general anti-avoidance rules (GAAR) in sections 80A to 80L of the Income Tax Act 58 of 1962 (the Income Tax Act) have featured in several recent judgments. The Constitutional Court has now delivered its judgment on two legal questions raised in the ABSA case....
Management fees: Is there a tax risk?

Management fees: Is there a tax risk?

by Pieter van der Zwan | Jul 18, 2022 | Corporate and business tax

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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