Search judgments by proposition, citation, court, judge or legal topic, then move directly into the source-grounded case analysis.
Results update automatically as you type.
South Africa decisions
Decisions matching the current search
Flower v Commissioner for the South African Revenue Service (IT 25209) [2025] ZATC 3 (3 February 2025)
The Tax Court held that SARS’s rule 31 statement impermissibly novated the assessment, allowed Flower’s pre-trade development fees, and rejected ring-fencing.
Taxpayer Trust Commissioner for the South African Revenue Service (IT 76795) [2025] ZATC 1 (13 January 2025)
The court held that the raising fees paid by the taxpayer to Sanlam for arranging loan facilities are 'interest or similar finance charges' as envisaged by section 24J(1) of the Income Tax Act. The definition of 'interest' in section 24J is intentionally broad, encompassing not only traditional interest but also charges that bear a relevant resemblance to interest, such as raising fees. The court found that the raising fees are closely connected to the loans, are calculated as a percentage of the capital raised, and are a condition for drawing down the loans. Differences in timing, periodicit…
Source excerpt
Explore more
