
Tax Court faults SARS in R158m VAT case over legal insurance fund
SARS’s stance on input VAT was overturned after the court found the fund to be the principal in an insurance agreement – not merely an agent.
SARS’s stance on input VAT was overturned after the court found the fund to be the principal in an insurance agreement – not merely an agent.
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.
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