- VAT ruling VR 012 issued on 30 May 2025 under the Value-Added Tax Act 89 of 1991
- Concerns sections 17(1) and 41B related to apportionment
- Ruling is specific to the Applicant, a holding company in electronics and electrical engineering
- Approves a varied turnover-based method for apportionment
- Applicant is a listed company in the Republic
- Activities include holding equity and preference shares, leasing space, and trading in manufacturing and engineering
- Income streams include inter-company dividends, preference dividends, and rental income
- Ruling allows inclusion of dividend income with specific variations
- Excludes interest on surplus funds, foreign exchange gains and losses, and profit/loss on share sales
- Effective from the 2023 financial year
- Subject to standard terms and conditions of the Tax Administration Act
- Apportionment ratio determined by a specific formula involving taxable and exempt supplies
Source: sars.gov.za
Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.
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