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GENERAL DEDUCTION FORMULA
Actually incurred
Where at the end of the tax year in which a
deduction is claimed, the outcome of the dispute is
undetermined, it cannot be said that a liability has
been actually incurred. The taxpayer could not
properly claim the deduction in that tax year, and
the Receiver of Revenue could not, in the light of
the onus provision of the Act, properly allow it.
(CIR v Golden Dumps (Pty) Ltd)
Onus provision: Section
102 of the Tax
Administration Act
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