A comparison of the application of the provisions in s 80A-80L with those of s 103(1) of the Income Tax Act 58 of 1962

Abstract

Tax avoidance is a key international tax issue. Combating tax avoidance has been placed high on the agenda by the South African Revenue Service (SARS) and other tax authorities in the world. This research report will examine how the judgments of certain South African cases would have been different if the anti-avoidance provisions in sections 80A to 80L were applied instead of those in section 103(1).