Natural Persons

Ordinarily resident status SARS interpretation note SARS has on 20 June 2018 reissued Interpretation Note 3 (Issue 2) (see 183 TSH 2018), setting out its interpretation of the expression ‘ordinarily resident’, appearing in the definition of ‘resident’ in s 1(1) of the...

The Special Voluntary Disclosure Programme

And estate duty on the assets in a nonresident trust Election and deemed holding For SVDP purposes, under s 18 of the Rates and Monetary Amounts and Amendment of Revenue Laws Act 13 of 2016, relief was granted to an applicant (donor or beneficiary) in circumstances in...

Understatement penalties – The SARS guide

A tax penalty, described in the Tax Administration Act as the ‘understatement penalty’ is imposed in circumstances dependent upon the taxpayer’s behaviour vis-à-vis an understatement. In essence, an understatement is a default, omission or incorrect statement in a...

Section 7C – Beneficiary awards and loans

Time for an advance ruling? The general rule under s 7C of the Income Tax Act is that a loan, advance or provision of credit by a natural person to a trust (or company) to which the lender is ‘connected’ (for example, a beneficiary) at a soft rate is subject to the...
Section 7C – Soft Loans to Trusts

Section 7C – Soft Loans to Trusts

PRACTICAL CONSIDERATIONS Timing provisions—dates A ‘s 7C donation’, as from 1 March 2017, is regarded as being made to a trust on the last day of each year of assessment of the trust, that is, for the first time, on the last day of February 2018 (s 7C(3)(b) of the...