
Can a tax deduction be claimed a decade late?
A fuel exporter lost a R38.8-million deduction claim, but the Tax Court ruling may open a fresh battle over whether the correct tax years can still be re-opened.

A fuel exporter lost a R38.8-million deduction claim, but the Tax Court ruling may open a fresh battle over whether the correct tax years can still be re-opened.

Taxpayers challenging assessments in transfer pricing disputes face hidden risks, including the rare possibility that the Tax Court could consider increasing an assessment.

The Court replaces the restrictive ‘exceptional circumstances’ test with a flexible ‘good cause’ standard, creating new forum-choice opportunities.