Page 34 - Taxation P6 - Lecture day 2 Notes - Trust

Interest free/low-interest loans

• The causal relationship between the failure to

charge (sufficient) interest and any income

received by or accrued to the trust or

beneficiaries could then result in the

application of s 7 (CIR v Berold).

• Also refer to CSARS v Woulidge(2000 (1) SA

600 (C).

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