IN 121–140

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.

Number	Subject	Applicable Legislation
IN 138 New!	Determining the calorific value of coal for purposes of the royalty	Mineral and Petroleum Resources Royalty Act 28 of 2008	Section 4(2) and Schedule 2
IN 137 New!	Recoupment of amounts deducted or set off when an asset commences to be held as trading stock	Income Tax Act, 1962	Sections 8(4)(a) and 8(4)(k)(iv)
IN 136	Public benefit organisations: Non-professional sport and recreation	Income Tax Act, 1962	Paragraph 9 in Part I of the Ninth Schedule
IN 135	Sale and leaseback arrangements	Income Tax Act, 1962	Sections 23D and 23G
IN 134	Disposal of assets by deceased person, deceased estate, and transfer of assets between spouses	Income Tax Act, 1962	Sections 9HA, 9HB and 25
IN 133	Income tax exemption: Water services provider	Income Tax Act, 1962	Section 1(1) and 10(1)(t)(ix)
IN 132	Persons not eligible to register as a tax practitioner and deregistration of registered tax practitioners for tax non-compliance	Tax Administration Act, 2011	Section 240(3)(d)
IN 131	Exemption of income relating to South African ships used in international shipping	Income Tax Act, 1962	Section 12Q
IN 130	Exemption for international aid received or accrued under an official development assistance agreement	Income Tax Act, 1962	Section 10(1)(yA)
IN 129	Understatement penalty: Meaning of “maximum tax rate applicable to the taxpayer”	Tax Administration Act, 2011	Section 222(5)
IN 128	Definition of “associated enterprise”	Income Tax Act, 1962	Section 31
IN 127	Determination of the taxable income of certain persons from international transactions: Intra-group loans	Income Tax Act, 1962	Section 31
IN 126	Extraordinary dividends treated as income or proceeds on the disposal of certain shares	Income Tax Act, 1962	Section 22B and paragraph 43A of the Eighth Schedule
IN 125	Associations: Funding requirement	Income Tax Act, 1962	Section 30B(2)(b)(ix)
IN 124	Public benefit organisations: Provision of residential care for retired persons	Income Tax Act, 1962	Paragraph 3(c) in Part I of the Ninth Schedule
IN 123	Effect on the date of issue of a share arising from a change in the redemption features	Income Tax Act, 1962	Section 8E
IN 122	Public benefit activity: Bid to host or hosting of any international event	Income Tax Act, 1962	Paragraph 11(b) in Part I in the Ninth Schedule
IN 121	Deduction of medical lump sum payments	Income Tax Act, 1962	Section 12M

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