Section 24C: The ‘contractual sameness’ requirement

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Pieter van der Zwan

Taxpayers may deduct an allowance for expenditure not yet incurred in terms of section 24C. In Clicks Retailers (Pty) Limited v Commissioner for the South African Revenue Service the Constitutional Court considered this provision’s requirement that the income and obligations for future expenditure must arise from the same contract. The judgment contains valuable guidance on the interpretation of the ‘contractual sameness’ requirement to be satisfied to qualify for the allowance.

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