IN 101 – 120

Interpretation notes are intended to provide guidelines to stakeholders (both internal and external) on the interpretation and application of the provisions of the legislation administered by the Commissioner.
These notes are amended when necessary in line with policy developments and changes in legislation, and will ultimately replace the existing general notes and practice notes, as well as internal circular minutes, to the extent that they relate to the interpretation of the various laws.
For an overview of all interpretation notes published to date, see the Register of all Interpretation Notes.
NumberSubjectApplicable Legislation
Prohibition of deductions in respect of certain intellectual property
Income Tax Act, 1962Section 23I
Deductions in respect of improvements to land or buildings not owned by a taxpayer
Income Tax Act, 1962Sections 12N and 12NA
Value-added tax consequences of points-based loyalty programmes
Value-Added Tax Act, 1991Section 1(1) Definitions of “consideration”, “input tax” and “supply”,
sections 7 and 10
Taxation of the receipt of deposits
Income Tax Act, 1962Section 1(1) – Definition of “gross income”
Withholding tax on royalties
Income Tax Act, 1962Sections 49A to 49H
IN 115 (Issue 2)
Withholding tax on interest
Income Tax Act, 1962Sections 50A to 50H
Interaction between section 25B(1) and section 7(8) ) in case of conflict, inconsistency or incompatibility
Income Tax Act, 1962Sections 25B(1) and
Apportionment of surplus and minimum benefit requirements: Pension Funds Second Amendment Act
Income Tax Act, 1962Section 1(1) – Definitions of  “pension” and “provident funds” and paragraph 2C of the Second Schedule
IN 112 (Issue 2)
Section 18A: Audit certificate
Income Tax Act, 1962Section 18A(2B) and (2C)
No-value provision in respect of the rendering of transport services by any employer
Income Tax Act, 1962Paragraph 10(2)(b) of the Seventh Schedule
IN 110 (Issue 2)
Leasehold improvements
Income Tax Act, 1962Paragraph (h) of the definition of “gross income” and
section 11(g) and (h)
IN 109 (Issue 2)
Lease premiums
Income Tax Act, 1962Paragraph (g) of the definition of “gross income” and
section 11(f) and (h)
Meaning of “bulk” in Schedule 2
Mineral and Petroleum Resources Royalty Act, 2008Schedule 2
IN 107 (Issue 2)Deduction in respect of commercial buildingsIncome Tax Act, 1962Section 13quin
IN 106 (Issue 2)Deduction in respect of certain residential unitsIncome Tax Act, 1962Section 13sex
IN 105
(Issue 2)
Deductions in respect of buildings used by hotel keepersIncome Tax Act, 1962Section 13bis
IN 104Exemption – Foreign pensions and transfersIncome Tax Act, 1962Section 10(1)(gC)(ii)
IN 103The value-added tax treatment of supplies of international and ancillary transport servicesValue-Added Tax Act, 1991Section 11(2)(a), (b), (c), (d) and (e)
IN 102 (Issue 2)Classification of risk policyIncome Tax Act, 1962Section 29A
IN 101 (Issue 2)
Gains or losses on foreign exchange transactions
Income Tax Act, 1962Section 24I

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