Section 24C : indicators regarding the certainty of the incurral of future expenditure

Date
2016
Journal Title
Journal ISSN
Volume Title
Publisher
AOSIS Publishing
Abstract
Section 24C of the Income Tax Act No. 58 of 1962 provides for a deduction of future expenditure that will be incurred by the taxpayer in the performance of his obligations under a contract from which the taxpayer derived income. The objective of this article is to compile a list of indicators demonstrating when there will be certainty that future expenditure will be incurred as aforementioned. The conclusion reached is that a definite connection must exist between the incurral of the future expenditure and the obligation to perform under the contract. Further, conditions and warranties are contractual terms that indicate that there is uncertainty regarding the taxpayer’s obligations to perform under the contract. A time clause in a contract and a high probability that the taxpayer will perform an unconditional obligation under a contract, however, both indicate that there is certainty regarding the incurral of future expenditure. A contingent liability to pay for future expenditure or if the future expenditure is unquantified are not indicators as to whether there is certainty that the future expenditure will be incurred.
Description
CITATION: Calitz, L. & Van Zyl, L. 2016. Section 24C : indicators regarding the certainty of the incurral of future expenditure. Journal of Economic and Financial Sciences, 9(1):174-193.
The original publication is available at https://jefjournal.org.za
Keywords
Income tax -- South Africa, South Africa. Tax Administration Act, 1962
Citation
Calitz, L. & Van Zyl, L. 2016. Section 24C : indicators regarding the certainty of the incurral of future expenditure. Journal of Economic and Financial Sciences, 9(1):174-193.