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South Africa decisions
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Taxpayer H v Commissioner for the South African Revenue Service (IT 14213) [2022] ZATC 5; 85 SATC 35 (9 February 2022)
The Tax Court held that Taxpayer H failed to prove a money-lending trade or income-production purpose for interest deductions, and upheld the understatement penalty.
Natal Laeveld Boerdery BK v Kommissaris van Binnelandse Inkomste (55/96) [1997] ZASCA 80; 1998 (1) SA 639 (SCA); [1998] 1 All SA 5 (A); (26 September 1997)
The court held that interest on a loan used to buy out a member of a close corporation was not deductible, because the dominant purpose was not income production.
Commissioner for Inland Revenue v Sunnyside Centre (Pty) Ltd. (86/95) [1996] ZASCA 102; 1997 (1) SA 68 (SCA); (20 September 1996)
The Supreme Court of Appeal held that the interest paid by Sunnyside Centre (Pty) Ltd to UBS in excess of interest received from SGH was not deductible under section 11(a) and section 23(g) of the Income Tax Act 58 of 1962. The Court found that the arrangement was primarily intended to benefit Agros (Pty) Ltd, another group company, by securing cheaper finance, and not to further Sunnyside's own trade or profitability. There was no evidence that Sunnyside intended to earn a profit from the transaction, nor that the expenditure was wholly and exclusively laid out for the purposes of its trade.…
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