Capital or revenue : a critical analysis of the treatment of realisation companies and the judgment of Lewis JA
The treatment of realisation companies is not directly dealt with by South Africa legislation and the jurisprudence focused thereon has developed in accordance with the needs of commercial entities to dispose of property. The relevant terms of our governing legislation has, in response to this solution, enveloped the idea of a realisation company through the results of the judicial system. In this paper the general income tax principles that relate to realisation companies will be evaluated. A synopsis will be provided, beginning with the locus classicus set out in the case of Berea West, thereafter the most recent case, Founders Hill, the effect thereof, and the general principles and cases exhibiting these principles, relating to the treatment of realisation companies by South African Court.
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