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AI summary
The Constitutional Court dealt with an appeal about the General Anti-Avoidance Rules in sections 80A to 80L of the Income Tax Act. It concerns preference share transactions entered into by Absa and its subsidiary, and SARS’ assessments for the 2014 to 2018 financial years. The appeal was dismissed with costs.
This may be relevant to tax practitioners and financial institutions dealing with GAAR assessments and the interpretation of “party” and “tax benefit” in avoidance arrangements.
Evidence from source
The appeal is dismissed with costs, including the costs of two counsel.
Supports: Summary sentence 3: the appeal outcome.