‘Instructive remarks’ from the Constitutional Court on understatement penalties
Expert legal interpretations, even if contrary to SARS’s stance, may not automatically result in understatement penalties.
Expert legal interpretations, even if contrary to SARS’s stance, may not automatically result in understatement penalties.
The court’s interpretation and application of the conduit principle has implications for structures involving layers of multiple discretionary trusts.
The tax dispute between ABD and SARS highlights the complexity of IP royalty pricing and the importance of expert testimony in transfer pricing audits.
The departure point in determining whether a company qualifies for the foreign business establishment tax exemption is what it actually does.
Coronation withdraws cautionary to shareholders following victory in litigation with SARS over the foreign business establishment tax exemption.
The ruling makes the Tax Courts more accessible, but there are risks to taking on SARS without a qualified and experienced legal representative.
The decision addresses the recovery of VAT on payments made under loan cover provided free of charge.