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Draft Interpretation Note on contingent liabilities

22 September 2015   (0 Comments)
Posted by: Author: SARS
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Author: SARS

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.

Depending on the quality of feedback received, SAIT will be making a submission to SARS. Kindly submit all comments to by no later than 15 December 2015 .


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