oa De Rebus - Substance versus form attack

Volume 1998, Issue 370
  • ISSN : 0250-0329



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 [1998] 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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