Prescription of self-assessed taxes arising from low-interest loans

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The Tax Administration Act makes provision for prescription of assessments. This ensures that taxpayers have finality in relation to assessments. The SCA recently considered the application of the prescription rules to an assessment for STC that was raised by SARS in circumstances where the taxpayer never submitted any return. Despite the fact that STC is no longer in effect, the views of the SCA are relevant in other instances where low-interest loans have tax implications.
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