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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 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. The Notes will be amended when necessary in line with policy developments and changes in legislation.
NumberSubjectApplicable Legislation
Section 24I – Gains or losses on foreign exchange transactions
Income Tax Act, 1962Sections 24I and sections 1(1) – definition of “trading stock”, 3(4)(b),
6quat(4), 8(4)(a),
9(2)(l), 9(4)(e), paragraph (c)(ii) and (iii) of the proviso to section 9D(2A), 9D(6), 9D(9)(fA)(ii) and (iii), 9D(9a)(a)(iii), 11(a), 11(i), 11(j), 19, 20(2), 22(3)(a)(i), 24J(2), (3) and (5A) and 25D, paragraphs 12A,
35(3)(a) and 43 of the Eighth Schedule and paragraph 4(1) of the Tenth Schedule
IN 102 (Issue 2)
Classification of risk policyIncome Tax Act, 1962Section 29A
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 104Exemption – Foreign pensions and transfersIncome Tax Act, 1962Section 10(1)(gC)(ii)
IN 105Deductions in respect of buildings used by hotelkeepersIncome Tax Act, 1962Section 13bis
IN 106Deduction in respect of certain residential unitsIncome Tax Act, 1962Section 13sex
IN 107Deduction in respect of commercial buildingsIncome Tax Act, 1962Section 13quin
IN 108Meaning of “bulk” in Schedule 2Mineral and Petroleum Resources Royalty Act, 2008Schedule 2
IN 109Lease premiumsIncome Tax Act, 1962Paragraph (g) of the definition of “gross income” and
section 11(f) and (h)
IN 110Leasehold improvementsIncome Tax Act, 1962Paragraph (h) of the definition of “gross income” and
section 11(g) and (h)
IN 111No-value provision in respect of the rendering of transport services by any employerIncome Tax Act, 1962Paragrah 10(2)(b) of the Seventh Schedule
IN 112Section 18A: Audit certificateIncome Tax Act, 1962Section 18A(2B) and (2C)
IN 113Apportionment of surplus and minimum benefit requirements: Pension Funds Second Amendment ActIncome Tax Act, 1962Section 1(1) – Definitions of  “pension” and “provident funds” and paragraph 2C of the Second Schedule
IN 114Interaction between section 25B(1) and section 7(8) ) in case of conflict, inconsistency or incompatibilityIncome Tax Act, 1962Sections 25B(1) and
IN 115Withholding tax on interestIncome Tax Act, 1962Sections 50A to 50H
IN 116Withholding tax on royaltiesIncome Tax Act, 1962Sections 49A to 49H
IN 117Taxation of the receipt of depositsIncome Tax Act, 1962Section 1(1) – Definition of “gross income”
IN 118Value-added tax consequences of points-based loyalty programmesValue-Added Tax Act, 1991

Section 1(1) Definitions of “consideration”, “input tax” and “supply”,
sections 7 and 10

IN 119Deductions in respect of improvements to land or buildings not owned by a taxpayerIncome Tax Act, 1962

Sections 12N and 12NA

IN 120
Prohibition of deductions in respect of certain intellectual propertyIncome Tax Act, 1962

Section 23I

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