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Tax Law [2025] ZATC 7

BCJ v Commissioner for the South African Revenue Service (2024/8)

BCJ v Commissioner for the South African Revenue Service (2024/8) [2025] ZATC 7 (23 May 2025)

The Tax Court held that SARS gave inadequate reasons for a GAAR assessment because it did not explain why the arrangement was said to occur in a business context.

  • General Anti Avoidance Rule
  • Impermissible Avoidance Arrangement
  • Adequacy Of Reasons
  • Income Tax Assessment
  • Commercial Substance
  • Business Context
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