In Taxpayer MLC v Commissioner for SARS (IT 77272) (the “MLC Case”), Eksteen J dismissed an appeal against a 150% understatement penalty for intentional tax evasion and ordered costs against the taxpayer. The outcome is unsurprising.
A special registration period enables parties to validly conclude customary marriages that were not registered within the prescribed period, thereby regularising their marital status.
In South Africa, section 31 of the Income Tax Act 58 of 1962 (“Income Tax Act”) applies the arm’s length principle to qualifying cross-border transactions, operations, schemes, agreements or understandings between relevant connected persons or associated enterprises.
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