Inhlakanipho Consultants (Pty) Ltd v CSARS

Supreme Court of Appeal dismisses reconsideration in Lutzkie v SARS, holding that no exceptional circumstances justified revisiting refusal of leave to appeal on disputed taxable income and penalties.

A practical training session on understatement penalties before and after 1 April 2026, covering the impact of the Coronation and Thistle cases, the BFIE amendment, and what the new rules mean for taxpayers and advisers.

A comprehensive analysis of Absa and Another v CSARS, examining SARS’s application of the General Anti-Avoidance Rules (GAAR) to complex preference share funding structures.

Binding Private Ruling 428 examines the income tax consequences of a Delayed Contribution Equity Investment Structure (DCEIS), confirming that phased share subscription proceeds constitute contributed tax capital rather than gross income.

The ruling also clarifies the interaction between sections 11D and 8(4)(a), confirming that qualifying R&D expenditure remains deductible without triggering recoupment consequences under the Income Tax Act.

In this practical training session, we unpack Tax Court judgment IT 24852 (Taxpayer EPP v SARS), where a taxpayer sought to deduct R38.8 million after customs and excise refund claims became time-barred. Explore the critical distinction between expenditure and loss under section 11(a), the timing of deductions, the impact of prescribed refund claims, understatement penalties, interest, and potential post-judgment remedies through reduced assessments and prescription exceptions under the Tax Administration Act

Debts are often written off or restructured in some way. These typically tend to have tax consequences. This session discusses what those tax consequences are.