THIRD-PARTY REPORTING AND AI: EXAMINING THE INCREASING BURDEN OF PROOF ON TAXPAYERS
In the landscape of modern tax administration, the principle that the burden of proof rests on the taxpayer is a fundamental tenet. This principle dictates that it is the taxpayer’s responsibility to substantiate their tax positions, despite the significant disparity in available resources between individual taxpayers and the government. While this framework aims to ensure […]
TRANSFER DUTY EXEMPTION AND CORPORATE TRANSACTIONS: ASSET FOR SHARE AND UNBUNDLING TRANSACTIONS
The Income Tax Act, No. 58 of 1962 (“the ITA”), contains certain provisions colloquially referred to as “the corporate roll over provisions”. In short, these provisions allow certain transactions to take place without triggering immediate adverse income tax (including capital gains tax), VAT, Transfer Duty or Securities Transfer Tax consequences. The taxes that would have […]
TAX TIP: R&D APPROVAL AFTER TAX RETURN SUBMISSION
To claim a deduction of 150% under section 11D of the Act, the taxpayer needs approval from the Minister of Science and Technology. Without the approval, the deduction cannot be claimed under section 11D. It often happens in practice, however, that R&D approval is granted only after the taxpayer’s year of assessment for which the […]