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Determining to what extent the “money-lender test” needs to be satisfied in the context of South African investment holding companies, focusing on the requirements of section 11(a) and 24J(2) of the Income Tax Act No. 58 of 1962
(Stellenbosch : Stellenbosch University, 2014-04)
ENGLISH ABSTRACT: The requirements of section 11(a) and section 24J(2) were considered in this research assignment, from both a money-lender’s and an investment holding company’s perspective, to determine whether interest, ...
Warranted and warrantless search and seizure in South African income tax law : the development, operation, constitutionality and remedies of a taxpayer
(Stellenbosch : Stellenbosch University, 2011-12)
ENGLISH ABSTRACT: Section 74D of the Income Tax Act No 58 of 1962 (the Act) grants the power of
search and seizure to the South African Revenue Service, the basic underlying
principle being that the Commissioner has to ...
Critical analysis of the components of the transfer pricing provisions contained in Section 31(2) of the Income Tax Act, no 58 of 1962
(Stellenbosch : University of Stellenbosch, 2004-12)
ENGLISH ABSTRACT: Despite the fact that transfer pricing legislation (i.e. section 31 of the Income Tax Act, 58
of 1962 (“the Act”) has been in force in South Africa since 1995, it has only been in the
last three years ...
An analysis of Section 80A(C)(ii) of the Income Tax Act no. 58 of 1962 as amended
(Stellenbosch : University of Stellenbosch, 2009-03)
ENGLISH ABSTRACT: In November 2006 section 103(1) of the Act was abolished and replaced by a
new Part IIA, containing sections 80A to 80L, which targets impermissible tax
avoidance arrangements. Section 80A(c)(ii) ...
An analysis of sections 11D(1)(A) and 11D(5)(B) of the income tax Act No. 58 of 1962 as amended
(Stellenbosch : Stellenbosch University, 2011-12)
ENGLISH ABSTRACT: In February 2007 section 11D was inserted into the Income Tax Act 58 of 1962 as
amended. The aim of the section was to encourage private-sector investment in
scientific or technological research and ...