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The utilisation of assessed losses by mining companies : critical analysis of the armgold/harmony freegold judgment

Dissertation (MCom)--University of Pretoria, 2013.

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Other Authors: Pienaar, S.J. (Sarah Johanna)
Format: Thesis
Language:English
Published: University of Pretoria 2014
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access_status_str Open Access
author2 Pienaar, S.J. (Sarah Johanna)
author_browse Pienaar, S.J. (Sarah Johanna)
author_facet Pienaar, S.J. (Sarah Johanna)
collection Thesis
dc_rights_str_mv © 2014 University of Pretoria. All rights reserved. The copyright in this work vests in the University of Pretoria. No part of this work may be reproduced or transmitted in any form or by any means, without the prior written permission of the University of Pretoria.
description Dissertation (MCom)--University of Pretoria, 2013.
format Thesis
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institution University of Pretoria (South Africa)
language English
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license_str Other — see source repository
provenance_str_mv Harvested via OAI-PMH from UPSpace — University of Pretoria Institutional Repository
publishDate 2014
publishDateRange 2014
publishDateSort 2014
publisher University of Pretoria
publisherStr University of Pretoria
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source_str UPSpace — University of Pretoria Institutional Repository
spelling oai:repository.up.ac.za:2263/41253 The utilisation of assessed losses by mining companies : critical analysis of the armgold/harmony freegold judgment Pienaar, S.J. (Sarah Johanna) mariska0408@gmail.com Booyse, Mariska Armgold/Harmony Freegold Assessed loss Mining tax Section 36(7F) Section 36(7E) Taxable income UCTD Dissertation (MCom)--University of Pretoria, 2013. The method of taking into account assessed losses in calculating the taxable income of mining companies is of significant importance following the Armgold/Harmony Freegold case. In this case, the court had to determine the method of calculating a mining company’s taxable income where at least one of its mines incurred a loss and where nonmining income was also derived. What constitutes an assessed loss, and the order in which it should be applied in calculating a mining company’s taxable income, was central to this case. In this study, the different approaches adopted by the parties to the case in order to determine whether there is an assessed loss, and the order in which it should be utilised in calculating taxable income, was analysed and compared to an analysis of the provisions of the Income Tax Act. In terms of this comparison, the judgment was found to be in accordance with the current legislation in the Income Tax Act. There is, however, a lack of updated guidance on matters relating to mining tax as is evident from the different interpretations of the provisions of the Income Tax Act by the parties to the case. Further research is therefore recommended in order to provide updated guidance to mining companies. am2014 Taxation unrestricted 2014-08-13T12:58:18Z 2014-08-13T12:58:18Z 2014-04 2013 Mini Dissertation Booyse, M 2014, The Utilisation of assessed losses by mining companies : critical analysis of the armgold/harmony freegold judgment, MCom dissertation, University of Pretoria, Pretoria, viewed yymmdd <http://hdl.handle.net/2263/41253> F14/4/450 http://hdl.handle.net/2263/41253 en © 2014 University of Pretoria. All rights reserved. The copyright in this work vests in the University of Pretoria. No part of this work may be reproduced or transmitted in any form or by any means, without the prior written permission of the University of Pretoria. application/pdf University of Pretoria
spellingShingle Armgold/Harmony Freegold
Assessed loss
Mining tax
Section 36(7F)
Section 36(7E)
Taxable income
UCTD
The utilisation of assessed losses by mining companies : critical analysis of the armgold/harmony freegold judgment
title The utilisation of assessed losses by mining companies : critical analysis of the armgold/harmony freegold judgment
title_full The utilisation of assessed losses by mining companies : critical analysis of the armgold/harmony freegold judgment
title_fullStr The utilisation of assessed losses by mining companies : critical analysis of the armgold/harmony freegold judgment
title_full_unstemmed The utilisation of assessed losses by mining companies : critical analysis of the armgold/harmony freegold judgment
title_short The utilisation of assessed losses by mining companies : critical analysis of the armgold/harmony freegold judgment
title_sort utilisation of assessed losses by mining companies critical analysis of the armgold harmony freegold judgment
topic Armgold/Harmony Freegold
Assessed loss
Mining tax
Section 36(7F)
Section 36(7E)
Taxable income
UCTD
url http://hdl.handle.net/2263/41253