Page 74 - P6 Slide Taxation - Lecture Day 7 - Various Topics

Source-Common law source principles

• If the source of a specific type of income is not

specified in the legislation, the source of the

income must be established by considering case

law.

• In light of the fact that South Africa applied a

sourcebased tax system previously, a large body

of case law exists on this subject.

• The authority in South Africa for the

determination of the source of an amount is

found in CIR v Lever Brothers & Unilever Ltd

(1946 AD) where Watermeyer CJ said:

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