IN 81 – 100

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
IN 81
(Issue 2)

Supply of goods and services by professional hunters and taxidermists to non-residents

Issue 2 makes reference to the withdrawal of Practice Note 13 of 6 September 1994, which had been inadvertently omitted from Issue 1
Value-Added Tax Act, 1991Sections 7(1)(a),
11(1)(a) and 11(2)(l)
IN 82

Input tax on motor cars

Replaced on 26 March 2015 after last bullet point under “Purpose” was removed
Value-Added Tax Act, 1991Sections 1(1), 17(2)(c) and 18
IN 83
(Issue 2)

Application of sections 20(7) and 21(5)

Issue 2 clarifies that it is VAT Practice Note 2 of 25 September 1991 that is being withdrawn
Value-Added Tax Act, 1991Sections 20(4), (5), (7),
21(1) and (5)
IN 84The value-added treatment of betsValue-Added Tax Act, 1991Sections 8(13), 9(3)(e), 10(17) and
IN 85The Master Currency case and zero-rating of supplies made to non-residentsValue-Added Tax Act, 1991Section 11(2)(l)
IN 86
(Issue 3)
Additional investment and training allowances for industrial policy projectsIncome Tax Act, 1962Sections 121
IN 87
(Issue 3)
Headquarter companiesIncome Tax Act, 1962Sections 1(1) – Definition of “headquarter company” and 9I
IN 88Tax deduction for amounts refundedIncome Tax Act, 1962Section 11(nA)
IN 89Maintenance orders and the tax-on-tax principleIncome Tax Act, 1962Section 7(11)
IN 90
(Issue 2
Year of assessment of a company: Accounts accepted to a date other than the last day of a company’s financial yearIncome Tax Act, 1962Sections 1(1), Definition of “financial year” and “year of assessment”, and
IN 91
(Issue 2)

Concession or compromise of a debt

Subject/title changed from Issue 2 onwards
Income Tax Act, 1962Section 19 and paragraph 12A of the Eighth Schedule
IN 92Documentary proof prescribed by the CommissionerValue-Added Tax Act, 1991Sections 16(2)(f) and
16(3)(c) to (n)
IN 93
(Issue 3)
The taxation of foreign dividendsIncome Tax Act, 1962Sections 1(1) – Definition of “foreign dividend” and 10B
IN 94Contingent liabilities assumed in the acquisition of a going concernIncome Tax Act, 1962Sections 1(1) (Definition of “gross income”) and 11(a), and paragraph 35(1) of the Eighth Schedule 
IN 95
(Issue 2)
Deduction for energy-efficiency savingsIncome Tax Act, 1962Section 12L
IN 96Exemption from income tax: Remuneration derived by a person as an officer or crew member of a South African shipIncome Tax Act, 1962Section 10(1)(o)(iA)
IN 97
(Issue 3)
Taxation of REITs and controlled companiesIncome Tax Act, 1962Sections 1(1) – Definition of “REIT” and 25BB
IN 98Public benefit organisations: The provision of funds, assets or other resources to any association of personsIncome Tax Act, 1962Sections  30(1), (3)(f) and Public Benefit Activity 10 in Part I of the Ninth Schedule
IN 99
(Issue 3)
Unclaimed benefitsIncome Tax Act, 1962Paragraph 4(1) of the Second Schedule
IN 100Meaning of “extracted”Mineral and Petroleum Resources Royalty Act, 2008Sections 1 and 6A(1)(b)

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