South Africa Case Law

Relier (Pty) Ltd. v Commissioner for Inland Revenue (256/96)

Relier (Pty) Ltd. v Commissioner for Inland Revenue (256/96) [1997] ZASCA 105; ; [1998] 1 All SA 183 (A); (25 November 1997)

Court

Supreme Court of Appeal

Case number

256/96

Judges

Harms, Mahomed, Van Heerden, Vivier, Zulman

The Supreme Court of Appeal held that a tax-driven leasing and subleasing arrangement was simulated, and that building costs were includible in Relier’s gross income.

• Gross Income Definition
• Simulated Transactions
• Tax Avoidance
• Income Tax Act Section 1
• Enforceable Rights
• Substance Over Form