Investments in foreign operations often include shareholder loans denominated in foreign currencies. Telkom disposed of such a shareholder loan at a substantial loss. It applied a disposal rate to deduct this as an exchange loss against its taxable income. SARS disallowed the deduction on the basis that it represented a loss that was beyond the scope of section 24I, which deals with gains or losses on foreign exchange transactions. The Supreme Court of Appeal considered this dispute and provided valuable guidance on the interpretation of tax legislation in the process. This article provides a brief review of this aspect of the judgment in the Telkom case.

The Budget Review published by the National Treasury on 26 February 2020 surprised many commentators when no significant tax rate increases were proposed. That document contains specific tax proposals that may have a significant impact on those affected by it. This article reviews a selection of these proposals that taxpayers should be aware of and look out for in the 2020 tax law amendment cycle.

Taxpayers may deduct an allowance for certain obligations to incur future expenditure in terms of section 24C of the Income Tax Act.  This provision has been the subject of a number of recent cases, the latest being C:SARS v Clicks Retailers (Pty) Ltd. In this case the SCA ruled in favour of SARS in relation to the application of section 24C to obligations in terms of a customer loyalty scheme. This article briefly reviews this case and the reasoning followed by the court.