SARS previously published a discussion paper on its preliminary views on the income tax implications for the seller and purchaser when a transaction is structured so that the purchase price of assets acquired as part of a going concern is settled or partly settled by the assumption of contingent liabilities.
This draft IN follows on from that discussion paper. The scope of the Note has been expanded to consider select aspects to the extent that the relief in corporate rules under sections 42 to 47 is applied in these circumstances.
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.