South Africa Case Law

Commissioner for the South African Revenue Service v Coronation Investment Management SA (Pty) Ltd (1269/2021)

Commissioner for the South African Revenue Service v Coronation Investment Management SA (Pty) Ltd (1269/2021) [2023] ZASCA 10; [2023] 2 All SA 44 (SCA); 2023 (3) SA 404 (SCA); 85 SATC 413 (7 February 2023)

Court

Supreme Court of Appeal

Case number

1269/2021

Judges

Makgoka JA, Nicholls JA, Nhlangulela AJJA, Salie AJJA, Mali AJJA

The Supreme Court of Appeal held that CGFM’s outsourced investment management remained its primary business, so it was not a foreign business establishment under section 9D.

• Controlled Foreign Company
• Foreign Business Establishment Exemption
• Income Tax Act Section 9d
• Tax Administration Act Understatement Penalty
• Outsourcing In Fund Management
• Controlled-foreign-company