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Synopsis Tax today - May 2021

A monthly journal, published by PwC South Africa, that gives informed commentary on current developments in the tax arena, both locally and internationally. 

Through analysis of and comment on new laws and judicial decisions of interest, Synopsis helps executives to identify developments and trends in tax law and revenue practice that may affect their business.

Two woman talking about the monthly synopsis publication

In this edition:

Another matter dealing with the interpretation of the provisions of section 24C of the Income Tax Act was recently considered in the Constitutional Court, which delivered judgment in the matter of Clicks Retailers (Pty) Ltd v CSARS [2021] ZACC 11. The findings in the Constitutional Court have advanced the interpretation of the law, but the burden of proof remains with the taxpayer to show that the contract that requires the taxpayer to incur expenditure in the future is the contract under which the income has been derived or is so inextricably linked to the income-earning contract that it satisfies the legal requirement of ‘sameness’.

In our second article we look at an interesting aspect which taxpayers should take note of being the impact of the change from IAS 39 to IFRS 9, particularly in the aftermath of Covid-19, in terms of which taxpayers have modified and restructured their debt/financial liabilities, resulting in a modification loss or gain. This article sets out how modification losses or gains should be treated for accounting and tax purposes as well as measures which could be taken, to the extent that taxpayers discover that they may not have disclosed the correct information to SARS.

Read more on this and other matters in the latest Synopsis below.


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Edition: Tax Synopsis - May 2021

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Al-Marie Chaffey

Al-Marie Chaffey

Senior Manager , PwC South Africa

Tel: +27 (0) 11 797 5644

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