The Taxpayer

CONTENTS

ARTICLE
OUTPUT TAX, GROSS INCOME, AND THE OPERATION OF THE ‘BENEFIT PRINCIPLE’ ………………………… 161

CASE LAW
VALUE-ADDED TAX – WHETHER A HOLDING COMPANY CONDUCTING AN ACTIVE INVESTMENT ENTERPRISE IS ENTITLED TO AN INPUT TAX DEDUCTION IN RELATION TO A RIGHTS OFFER MADE TO SHAREHOLDERS TO RAISE CAPITAL FOR FURTHER INVESTMENT …………………….. 167

VALUE-ADDED TAX – WHETHER THE TAX COURT HAD JURISDICTION TO HEAR AN APPEAL AGAINST A DECISION BY SARS MAKING AN APPORTIONMENT METHOD RULING OTHER THAN THE METHOD REQUESTED BY THE VENDOR ……. 181

TRANSFER PRICING – THE CONSTITUTIONAL COURT ON WHETHER A PARTICULAR TAXPAYER HAD BEEN ENTITLED TO A SECTION 105 DIRECTION IN RELATION TO RELIEF SOUGHT BY IT IN THE HIGH COURT …………………… 190