Interesting decision on deduction of remuneration repayments
though not relevant in SA anymore after s11(nA) & (nB) were inserted. May
only be relevant in so far the unsuccessful argument that remuneration accrual
in this instance is retrospectively novated by the resolutive pay back
provision. Also relevant as to whether the nature of the payment changes (i.e.
refund of previous amount or damages for breach).
Section 240A of the Tax Administration Act, 2011 (as amended) requires that all tax practitioners register with a recognized controlling body before 1 July 2013. It is a criminal offense to not register with both a recognized controlling body and SARS.