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New facts, same tax dispute: the Tax Court opens the door
A recurring difficulty in tax disputes is how far a taxpayer may develop its case after lodging an objection. SARS understandably wants taxpayers to put their cards on the table early.
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Fraudulent eFiling returns and the 150% penalty
In Taxpayer MLC v Commissioner for SARS (IT 77272) (the “MLC Case”), Eksteen J dismissed an appeal against a 150% understatement penalty for intentional tax evasion and ordered costs against the taxpayer. The outcome is unsurprising.
NEWSFLASH: Registered or unregistered? What South African married parties to a customary marriage need to know
A special registration period enables parties to validly conclude customary marriages that were not registered within the prescribed period, thereby regularising their marital status.
DEMPE and transfer pricing for intellectual property
In South Africa, section 31 of the Income Tax Act 58 of 1962 (“Income Tax Act”) applies the arm’s length principle to qualifying cross-border transactions, operations, schemes, agreements or understandings between relevant connected persons or associated enterprises.
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