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We provide a wealth of publications by PwC South Africa providing informed commentary on current developments in the tax arena, both locally and internationally.
Through analysis and comment on new law and judicial decisions of interest, they assist business executives to identify developments and trends in tax law and revenue practice that might impact their business.
Tax Alert - CSARS v Woolworths – VAT victory on deductibility of capital-raising costs for active investment holding companies
The Supreme Court of Appeal (“SCA”) delivered its judgment on 4 July 2025, confirming Woolworths Holdings Limited’s entitlement to deduct input tax on costs incurred for underwriting services relating to a rights offer to raise capital for the purpose of acquiring shares in David Jones Limited. In addition, the SCA ruled that the services from non-resident providers were not subject to VAT on imported services and set aside the understatement penalty imposed by SARS.