Abstract
Section 24C of the Income Tax Act No. 58 of 1962, (the Act) has been part of South African law for more than three decades. The Commissioner (the Commissioner) for the South African Revenue Service (SARS) pre-empted an initial interpretation and rationale of S 24C in the Explanatory Memorandum on the Income Tax Bill of 1980 (the Explanatory Memorandum), wherein the purpose of S 24C was to provide relief to those taxpayers that have purported ‘timing differences’, when a taxpayer incurs any future expenditure based on a contract entered into with other contracting parties (SARS, 1980)...
M.Com. (South African and International Tax)