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Is it practically possible to comply with the qualifying interest requirement when entering into a section 42 asset-for-share transaction concerning immovable property, given the applicable time of disposal rules and the application of the Companies Act?
The South African Income Tax Act No 58 of 1962 (“the ITA”) contains several group relief provisions aimed to facilitate corporate restructuring. In the ITA there are various examples of roll-over relief provisions generally that contain no time restrictions, nor which are determined with reference t...
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| Language: | English English |
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Department of Finance and Tax
2025
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