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2019

18 01 2019

BPR: TAXABILITY OF INTEREST WHERE DTA BETWEEN SA AND BRAZIL APPLIES

A Binding Private Ruling (BPR) 307 was issued by the South African Revenue Service on 4 July 2018 which deals with the application of DTA relief in respect of the double taxation of interest.

18 01 2019

DEDUCTION FOR PHOTOVOLTAIC SOLAR ENERGY PLANTS

Section 12B(1) and (2) of the Income Tax Act provides for a 50/30/20 income tax deduction in respect of certain machinery or plant owned by the taxpayer and which was or is brought into use for the first time by that taxpayer, for the purpose of his or her trade to be used by that taxpayer in the generation of electricity from, amongst others, photovoltaic solar energy (both for energy of more than 1 megawatt and energy not exceeding 1 megawatt) or concentrated solar energy. The tax deduction also applies to any improvements to the qualifying plant or machinery which is not repairs.

18 01 2019

RING-FENCING OF ASSESSED LOSSES OF CERTAIN TRADES

Persons are generally allowed to set off any losses incurred in respect of one trade against the income derived from another trade, thereby reducing their overall tax liability.

18 01 2019

SIMULATED TRANSACTIONS – IMPORTANT JUDGEMENT BY THE SCA

The Supreme Court of Appeal (SCA) handed down an important judgement on 9 November 2018 in the case of Sasol Oil v CSARS (923/2017) [2018] ZASCA 153 which deals with simulated transactions and anti-avoidance schemes.

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