oa De Rebus - Substance versus form attack
|Article Title||Substance versus form attack|
|© Publisher:||Law Society of South Africa|
|Publication Date||Nov 1998|
|Pages||63 - 64|
|Keyword(s)||Commissioner for Inland Revenue|
The Commissioner is not always successful - ITC 1625 With the recent Erf 3183/1 Ladysmith (Pty) Ltd and Another v Commissioner for Inland Revenue 1996 (3) SA 942 (A) and Relier (Pry) Limited v Commissioner for Inland Revenue  1 All SA 183 (A) cases, where the Commissioner for Inland Revenue (CIR) was successful in a substance versus form attack on two over-elaborate tax schemes, many tax consultants were of the opinion that, whenever the CIR instituted a substance versus form attack , the taxpayer would be hard-pressed to resist.
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