The Resource Crookes Brothers Ltd v Commissioner for the South African Revenue Service : Case No 14179/2017

Crookes Brothers Ltd v Commissioner for the South African Revenue Service : Case No 14179/2017

Label
Crookes Brothers Ltd v Commissioner for the South African Revenue Service : Case No 14179/2017
Title
Crookes Brothers Ltd v Commissioner for the South African Revenue Service : Case No 14179/2017
Contributor
Subject
Language
  • eng
  • eng
Summary
Judgment by the High Court of South Africa, decision date 8 May 2017. This is the first case in South Africa on the transfer pricing legislation contained in s 31 of the Income Tax Act 1962. A South African company made an interest-free loan to its 100% subsidiary in Mozambique. The South African legislation required the company to impute an interest income, and also to make a secondary adjustment of the equivalent of a dividend. The South African company made these adjustments, then became aware that there was an exception in s 31(7) of the Act. When the company sought to make an amended assessment to take advantage of this exception, SARS responded that the conditions for the exception did not apply. The judge agreed with SARS
Citation source
In: International tax law reports. - London. - Vol. 21 (2018), part 2 ; p. 210-218
Geographic coverage
Africa
Language note
English
http://library.link/vocab/relatedWorkOrContributorName
Baker, P
http://library.link/vocab/subjectName
  • case law
  • transfer pricing
  • error
  • intercompany loan
  • tax treaty
Label
Crookes Brothers Ltd v Commissioner for the South African Revenue Service : Case No 14179/2017
Link
https://library.ibfd.org/custom/web/SD_PDF/scans/2018/G-I/ITLR/2_210-218.pdf
Publication
Note
20190118

Library Locations

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      52.3736660 4.9336932
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