11 September 2026 – Income Tax Act, 1962
Capital gain tax (CGT) on transfer or migration of shares in a trust to non-resident trust: Whether the Appellant has met the burden of proving that SARS was not entitled to assess it for CGT in relation to a disposal of assets which occurred in the 2018 year of assessment – whether the Appellant is entitled to a remission of interest imposed in terms of the Income Tax Act, 1962 (the Act) – whether the appellant is entitled to a remission of penalties imposed in terms of the Act; and whether SARS is correct in imposing an understatement penalty of 10% on the levying of CGT on the disposal in question.
