SynopsisApril 2007

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It has recently been reported in thepress that SARS has lodged a claimfor R183 million in income tax againstthe estate of the slain miningmagnate, Brett Kebble in respect ofthe R2 billion allegedly stolen by himfrom the mining companies of whichhe was a director. It is further reported that the Master of the High Court hasrejected the claim on the grounds that the amounts on which SARS soughtto levy tax constituted money stolenby Kebble, and that stolen money isnot subject to income tax.

It has been reported that SARS is totake the Master’s decision in thisregard on review.

Why the issue is being contested on the basis of review, as distinct from theordinary process of assessmentfollowed by objection and appeal, is not clear. An appeal is concerned only withthe regularity of the process by which adecision was reached, not with thecorrectness of the decision itself.

A moot point of tax law

The Kebble case raises an interestingand unresolved tax issue and, in viewof the large sum at stake, it may be acase that will go all the way to theSupreme Court of Appeal and bringlong-overdue certainty to the law.

The Income Tax Act is of noassistance in determining the issue. Section 23(o) states that paymentsthat are illegal in terms of chapter 2 of

the Prevention and Combating ofCorrupt Activities Act 12 of 2004 orthat constitute a fine or penalty forany unlawful activity carried out in theRepublic (or in any other country ifthat activity would be unlawful ifcarried out in the Republic) are notdeductible for income tax purposes.

There is, however, nothing in theIncome Tax Act to say that therecipient of corrupt or illegalpayments is (or is not) not subject toincome tax on such amounts, and this issue must, therefore, be resolved bythe application of common law, that is to say, in terms of principles laiddown by the courts.

In COT v G 1981 (4) SA 167 theAppellate Division of Zimbabwe heldthat a person who steals money doesnot “receive” it in the sensecontemplated in the definition of“gross income” in the Income Tax Act, because he does not acquire themoney “on his own behalf and for hisown benefit”.

Is a thief liable for incometax on stolen money?Many thorny issues

In this issue

Is a thief liable for income tax on stolen money? . . . . . . . . . . . 2

Small business tax amnesty window closes soon . . . . . . . . . 4

PBOs will no longer be required to register as NPOs. . . 5

Restraint of trade payments - dubious bictory for taxpayer . . . 6

SCA refuses condonation for late filing. . . . . . . . . . . . . . . 10

Tax write-off regulations published . . . . . . . . . . . . . . . . 12

Increase in jurisdiction for Tax Board . . . . . . . . . . . . . . . . 12

SARS publishes STC guide. . . 12

Guide to new tax regime forrecreational clubs . . . . . . . . . . 12

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If this is correct, then the question ofwhether or not such an amount “isincome” does not arise, since it is only once an amount has been received oraccrued that the issue arises as towhether it is income or capital.

However, the correctness of thisdecision is suspect. Certainly, from the thief’s perspective, the reason why hestole the money was precisely toacquire it “for his own benefit” and the interpretation that the judge accordedthis phrase is, with respect, legalistic,artificial and unsupported by authority.

In ITC 1789 (2005) SATC 205, wherethe taxpayer in question had solicitedmillions of rand from a multitude ofinvestors in a fraudulent and unlawfulscheme, the court held that thosemoneys had been “received” ascontemplated in the definition of‘gross income’.

If both of these decisions are goodlaw, it would mean that (as was held in ITC 1789) a person who systematically cheats others out of money is subjectto income tax on his booty, but that(as was held in G v COT) a person who actually steals money in a systematicway is not taxable. This, it issubmitted, is a preposterous anduntenable distinction.

The true issue was whether theamounts were “income”

It is submitted that both these casesought to have been decided on the

basis of whether, in the particularcircumstances, the amounts inquestion had the character of“income” in the hands of the felon,rather than on the issue of whether ornot the moneys had been “received”by him. Beneficial receipt was surelyself-evident in both cases. It can hardly be seriously contended that a thief orconfidence trickster does not intend toacquire the victim’s money for his ownbenefit, and treat it as his own.

The issue of whether money that has

been stolen or is otherwise tainted with

illegality is “income” in the hands of the

recipient and is therefore subject to

income tax, raises many thorny issues,

never to date fully addressed let alone

resolved by our courts.

Some of the aspects of the issue as to

whether illegal receipts are taxable as

income are –

· Illegal receipts range from those that

are tainted with a mere technical

illegality, such as those derived from

trading without a licence, to morally

reprehensible receipts such as the

proceeds of drug-dealing or a fee

paid to a hit-man for carrying out an

assassination. In the tax context, do

the same principles apply to every

kind of illegal receipt?

· If SARS were to take a slice of an

illegal receipt, would this not make

the State complicit in the illegality?

· If income tax were to be imposed on the recipient of stolen money, thiswould reduce the funds available torepay the rightful owner. It needs tobe remembered that, in law,ownership of the money has passedto the thief, and all that the ownerhas is a claim in personam againstthe thief for repayment. If the thiefhas spent the money and is unableto repay it, the victim is merely aconcurrent creditor in the thief’sinsolvent estate.

SARS, by contrast, has a preferentialclaim, in terms of the Insolvency Act, for any taxes due. If income tax were payable on the stolen money, it isthus conceivable that SARS wouldrecover all or some of the tax, butthat the victim would not get hismoney back. This, it is submitted, isan unpalatable result.

Should SARS get involved at all?

There is a strong argument that, whereillegal payments are concerned –certainly in regard to stolen money – itwould be preferable for tax law tostand aloof, attach no taxconsequences to the receipt of themoney, and let the whole matter bedecided in terms of criminal law.

However, in view of the uncertainty inthe law on this point, SARS can hardly be faulted for asserting a claim.

There is a strong argument that, where illegal payments are concerned it would be preferable for tax law to stand aloof, attach no tax consequences to the receipt of the money, and let the wholematter be decided in terms of criminal law.

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Small business tax amnesty window closes soon!

The amnesty window period for businesses with a turnover of less thanR10 millon per annum expires on 31 May 2007.

To date SARS has received almost 18 000 applications for amnesty. After the deadline,

SARS will assume a vigorous enforcement campaign against businesses that are not tax

compliant.

Should you require more information on whether you qualify, application information or the

scope of the tax amnesty relief, contact your local PwC tax representative or Bennie Botha

on (012) 429-0292.

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Tight controls imposed on tax-exempt Public Benefit Organisations by the Income Tax Actrender additional requirements of the Non-Profit Organisations Act unnecessary.

The Minutes of the Finance Portfolio Committee meetingof 20 October 2006 reveal that section 30(3)(g) of theIncome Tax Act 58 of 1962 is to be repealed, to abolishthe requirement that a public benefit organisation, whichseeks the approval of the Commissioner, also has toregister as a non-profit organisation in terms of theNon-Profit Organisations Act 71 of 1997.

This change is to be welcomed.

The tax regime which accords exempt status to charitableand other non-profit organisations has gone from extremelaxness to stringent control with the enactment of section30 of the Income Tax Act, read with section 10(cN).

One consequence of this tightening-up is that manyworthy but cash-strapped public benefit organisationshave to outlay substantial sums for professional advice on

how to structure themselves and conduct their activities in order to secure and maintain tax-exempt status. Andconsiderable legal expertise is required to draft a PBO’sconstitution so as to comply with section 30(3)(b) of theIncome Tax Act. Certainly, this could not be done by theaverage lay person.

In addition, application has hitherto had to be made for

registration in terms of the Non-Profit Organisations Act

and further paperwork completed in this regard. There has

also been the on-going compliance burden of lodging an

annual narrative report of the entity’s activities in terms of

section 18(1)(a) of the Non-Profit Organisations Act.

Given the tight controls imposed on tax-exempt PBOs by

the Income Tax Act, the additional requirements of the

Non-Profit Organisations Act served little purpose.

PBOs will no longer be required toregister as NPOs

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A pre-2000 restraint of trade payment under the spotlight

ITC 1816 (2007) 69 SATC 62, a decision of the Gauteng Tax Court,

concerned the taxability of a payment in restraint of trade made by a bank

to an employee.

This taxpayer, a chartered accountant who was employed by a bank as astructured finance specialist, was offered a restraint of trade agreement, which was duly entered into in 1999. In terms of this agreement, the bank thatemployed her agreed to pay her R1.1 million in return for which she undertooknot to enter the service of another merchant bank for one year after leaving the bank’s employ.

The first tranche of the R1.1 million, amounting to R440 000, was paid on25 October 1999 (part of which the taxpayer used to repay a loan from thebank which she had taken out to acquire shares in the bank in terms of a share incentive scheme). She was then retrenched in August 2001. The secondtranche of R660 000 was paid to her on 30 September 2001. The balance ofR99 000 had been paid into her bank account on 3 November 1999.

The taxpayer disclosed the restraint of trade agreement in her tax return.

Payments in restraint of tradeDubious victory for taxpayer

It is generally accepted that a

payment in consideration for

agreeing to a restraint of trade is a

receipt of a capital nature (see

Tuck v CIR 1988 (3) SA 819 (A)).

The potential of such payments to

escape income tax has been

radically curtailed by the

enactment of paragraph (cA) of the

definition of “gross income” in

section 1 of the Income Tax Act 58

of 1962, which provides that gross

income includes –

“any amount received by or

accrued to any person who –

(i) is a natural person;

(iii) is or was a labour broker …;

(iv) is or was a personal service

company …;

(v) is or was a personal service trust

…”

as compensation for a restraint of

trade imposed on such person”.

Paragraph (cA) was inserted in the

Act in 2000 and applies to any

amount received or accrued on or

after 23 February 2000.

Hence, so far as natural persons

are concerned, the tax-avoiding

potential of payments in restraint

of trade is confined to amounts

received or accrued prior to that

date. Amounts accruing thereafter

in terms of a restraint of trade

agreement are subject to income

tax in the hands of individuals, but

remain capital in the hands of

juristic persons other than labour

brokers, personal service

companies and trusts.

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In respect of the 2000 tax year, SARS initially issued an assessment that did not include any amount of therestraint of trade payment in thetaxpayer’s gross income. Thereafter,an additional assessment was issued, which included the full amount ofR1.1 million in the taxpayer’s grossincome for that year.

The taxpayer requested reasons forthe additional assessment, in reply towhich SARS contended that the R1.1million was taxable in terms ofparagraph (c) of gross income (whichprovides that a taxpayer’s grossincome includes “any amount …received or accrued in respect ofservices rendered or to be rendered”)and that “the true reason” for therestraint of trade agreement was “tocompensate the employee forservices rendered/to be rendered and to retain such services of the

employee” and, furthermore, that thefull amount of R1.1 million accruedduring the 2000 tax year.

The issues and the evidence

The court regarded the central issueto be whether the restraint of tradeagreement entered into between thetaxpayer and the bank whichemployed her was “a genuineagreement”. (See the judgment atparagraph 16.)

In terms of the restraint of tradeagreement, the taxpayer was

precluded from working in “merchantbanking” for one year after she leftthe bank’s employ. (See the judgment at paragraph 35.)

The CEO of the bank testified that the restraint of trade agreement wasgenuine and that the parties fullyexpected its terms to be compliedwith.

He said that the bank’s shareincentive scheme – which had beenintroduced “to incentivise and retainkey employees” – had not beenworking properly because the shareprice had dropped and the interestaccruing on the considerationpayable by the participants in thescheme was making the schemeunattractive.

The bank, he said, “was faced withthe real danger of losing key peoplewho would take valuable knowledge

with them. The RTA was used tosecure employees and the mainobjective was to make it difficult foremployees to leave”. The heavyinterest accumulating on the shareoption scheme meant that keypersonnel “could be tempted to leave the bank and take their know-howand proprietary knowledge withthem” (See the judgment atparagraphs 43 – 46, 59.)

The judge commented that, “It is wellknown in commercial circles thatexecutive share incentive schemesprove very effective ‘golden

handcuffs’ which not only incentiviseexecutive staff but also bind them tothe company”. (Paragraph 62.)

In determining whether the restraint of trade agreement was simulated, thecourt said (see paragraphs 28 – 29)that “the critical inquiry … is theappellant’s true intention” in enteringinto the agreement. In this regard, the court quoted from the judgment inMackay v Fey NO 2006 (3) SA 182 inwhich the Supreme Court of Appealheld that –

“a transaction which is disguised … is

essentially a dishonest transaction; the object

of the disguise, which is common to the

parties, is to deceive the outside world. Before

a court will hold a transaction to be simulated

or dishonest in this sense it must therefore be

satisfied that there is some unexpressed or

tacit understanding between the parties to the

agreement which has been deliberately

concealed.”

Critical analysis

As was noted, above, the court saidthat the central issue was whether the restraint of trade agreement “was agenuine agreement”. (See thejudgment at paragraph 16.) But howdo you decide whether it was a“genuine agreement”? Do you simplyask – did the parties genuinely intendto honour their respectivecommitments under the agreement.In particular, did the taxpayergenuinely intend, having pocketed the R1.1 million, not to take upemployment with a merchant bank if

The judge commented that, “It is well known in commercial circles that executive share incentive schemes prove very effective ‘golden handcuffs’ which not only incentivise executive staff but also bind them to the company”.

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she left her current employment? Ifthat is all that the inquiry involves,then the facts spoke for themselves.When the taxpayer was retrenched,she did not go and work for amerchant bank for the one year of the restraint, even though she apparentlyreceived offers. (See paragraph 36 ofthe judgment.)

I would argue, however, that thecentral issue goes beyond the“genuineness” of the agreement andshould take account of the precisenature of the bargain between the

parties and the capital or revenuenature of the amount paid to thetaxpayer.

A restraint of trade agreementis not enforceable unless itprotects a proprietary interest

The law recognises that a restraint oftrade agreement is not legallyenforceable unless it intends toprotect an employer’s proprietaryinterests. An agreement that merelyseeks to prevent an erstwhileemployee from utilising the skills andknowledge learned on the job in theservice of someone else is not legallyenforceable. (See Automotive ToolingSystems (Pty) Ltd v SJ Wilkens [2006]128 (RSA).)

In the present case, there is a briefmention in the judgment (atparagraph 59) of the bank’s fear thatkey employees “could be tempted toleave the bank and take theirknow-how and proprietary knowledge

with them”. But there is noexplanation as to what this“knowledge” was, and why it was“proprietary” in nature. No evidenceseems to have been led to identify the proprietary right which the restraintwas intended to protect.

The key question (it is submitted) iswhether the payment made to thetaxpayer in this case was capital orrevenue in her hands. That questioncannot be answered simply bylabelling the agreement in terms ofwhich it was paid a “restraint of tradeagreement” or by airy references to“knowledge” acquired by her.

Let us approach the question fromthe point of view of the payer bank.From its point of view, was thepayment an outgoing of a capitalnature? In other words, was itintended to strengthen the structureof the bank’s business? In this regard, there is clear authority thatexpenditure incurred in order to shield

the taxpayer’s business fromcompetition is expenditure incurred to protect the structure of the taxpayer’s business, and is therefore of a capitalnature. (See CIR v African Oxygen Ltd 1963 (1) SA 681 (A), 25 SATC 67.)

In the present case, did the bankintend the payment to the taxpayer to protect the structure of the bank’sbusiness by shielding it fromcompetition? We do not know theanswer because no evidence was ledon the point.

The judgment tells us that the CEO ofthe bank testified that the purpose ofthe agreement in question was to“incentivise and retain keyemployees”. (See the judgment atparagraph 45.) This witness did, it istrue, make an unsubstantiatedassertion that the bank was concerned that key employees might resign andtake “proprietary knowledge” withthem. Nothing in the judgment shedsany light on what that “proprietaryknowledge” was, and it is difficult toimagine that the kind of knowledgethat a chartered accountant, such asthe taxpayer in this case, possesseswould ordinarily fall into that category.

Moreover, this witness said that the“main objective” of the restraint oftrade agreement was “to make itdifficult for employees to leave”;hence, protecting the bank fromcompetition or from the disclosure ofin-house knowledge seems to havebeen a subsidiary consideration.

The key question as to whether the payment was capital or revenue cannot be answered simply byairy references to “knowledge” acquired.

Restraint of trade payments

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The critical distinction, well-establishedin case law, between mere “know-how” or “skills and abilities”, on the onehand, and “proprietary rights” on theother, is not drawn in the judgment.(See Automotive Tooling Sysems (Pty)Ltd v SJ Wilkens [2006] 128 (RSA) atparagraph [9].)

In short, there is nothing beyond abare hint in the judgment to suggestthat, from the bank’s point of view,the payment of the R1.1 millionsecured for it an advantage of acapital nature, that is to say, a benefitwhich strengthened the structure ofthe bank’s business.

Of course, the fact that expenditure is not of a capital nature from thepayer’s perspective does notestablish whether its receipt is capital in the hands of the payee, but it doesthrow light on the nature of theagreement.

Was the receipt of R1.1 milliona capital receipt?

The critical question in the presentcase was: did the receipt of the R1.1 million constitute a capitalreceipt in the hands of the taxpayer?

The only basis on which it could beargued to be of capital nature wouldbe if the restraint of trade agreementhad the effect of “sterilising” a capitalasset that the taxpayer possessed, inother words rendering a capital assetof hers unproductive for a significantperiod. (Compare CIR v Illovo SugarEstates Ltd 1951 (1) SA 306 (N);Taeuber and Corssen (Pty) Ltd v SIR1975 (3) SA 649 (A).)

Indeed, this was recognised by thecourt in the present case, for thejudgment records (at paragraph 61)that the taxpayer testified that “shehad intimate knowledge which was

sensitive to the Bank and valuable toits competitors and the Bank soughtto sterilise this information in herpossession”.

From this juncture, the judgmentsimply assumes that “intimateknowledge” which was “sensitive”and which could be “valuable to [thebank’s] competitors” was, ergo, acapital asset in the hands of thetaxpayer, and that her agreement notto be employed in merchant bankingfor a year after leaving the bank’semploy constituted a “sterilisation” ofthat capital asset.

With respect, these assertions wereneither (so far as appears from thejudgment) backed by evidence, norare they supported by legal authority.The judgment nowhere cites anyevidence placed before the court thatestablished the nature of this“intimate” and “sensitive” knowledge, nor does the judgment cite authorityas to why that knowledge was, in law, of a capital nature. Knowledge is notipso facto “capital”; see the dicta ofSteyn CJ in Smith v SIR 1968 (2) SA480 (A) at 489G in regard to whatconstitutes “capital” in the tax context.

In the absence of factual evidence asto the nature of the knowledgepossessed by the taxpayer in thiscase, and in the absence of anyreasoned argument in the judgmentthat the law regards knowledge ofthat kind as “capital” and that anagreement not to utilise theknowledge for a limited period would, in law, constitute the “sterilisation” ofa capital asset, the judgment remainsunpersuasive in its conclusion thatthe quid pro quo paid to the taxpayerin this case was of a capital nature.

The only basis on which it could be argued to be of capi talnature would be if the restraint of trade agree ment had theeffect of “steri lis ing” a capi tal asset that the taxpayerpossessed ...

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The background to the decision of the Supreme Court of Appeal in CSARS vLevue Investments (Pty) Ltd [2007] SCA 22 RSA was an order, granted by theJohannesburg High Court, which the SCA described as “unprecedented”.

In effect, the High Court had ordered SARS to make a VAT refund of someR2.5 million to a taxpayer in circumstances where SARS was still weighing upwhether or not to concede the taxpayer’s objection, lodged in terms of section32(4) of the Value-Added Tax Act, to a disallowed claim for a refund of VAT.

The procedural aspects of anappeal to the courts must be strictly adhered to. Non-compliance willnot necessarily be condoned by the court even if the party in default has a good prospect of success.

The SCA refuses condonation for late filingTardiness not tolerated

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As the SCA pointed out, “It isunprecedented that where a creditorseeks to recover a disputed debt from a debtor, the latter can be ordered,pending resolution of the dispute, topay the debt”.

SARS, not unnaturally, lodged anappeal to the SCA against the orderof the Johannesburg High Court, andthe prospects of success in thatappeal seem to have been assured.

However, in prosecuting the appeal to the Supreme Court of Appeal, SARS’s attorneys were extraordinarily tardy in filing the record of the proceedings inthe Johannesburg High Court. In factit took ten months for the record,which ran to only 119 pages, to befiled. The attorneys had delayed fornearly two months in even requestingthat the record be typed and collated.

In terms of the rules of court, theappeal to the Supreme Court ofAppeal lapsed by reason of the failure to file the record in the court belowtimeously. SARS applied to the SCAfor condonation of the late filing andfor reinstatement of the lapsedappeal.

The Supreme Court of Appeal refused the application for condonation of the late filing of the record, pointing outthat it has –

“repeatedly warned that a partyseeking condonation [ofnon-compliance with the rules ofcourt] cannot rely solely on prospects of success to entitle it to be excusedfor not complying with the rules.”

In other words, although SARS hadexcellent – indeed overwhelming –

prospects of success in its appealagainst the astonishing order madeby the Johannesburg High Court,this factor alone did not justify failureto abide by the time limits and otherprocedural steps which the rules ofcourt require to be followed in anappeal.

The decision of the SCA thereforepermanently scuttled SARS’sattempt to have the judgment of theJohannesburg High Court set aside,and in effect obliged SARS toprovide the taxpayer with an interimrefund of the VAT in issue, pendingresolution of the dispute between the parties as to whether or not VATwas, in the circumstances of thematter, indeed refundable.

The decision of the SCA does not,

however, debar SARS fromcontesting, in the Tax Court andbeyond, the principal issue indispute, namely whether the VAT inquestion was refundable. If SARSachieves ultimate success, it will beable to recover the VAT that it has, inthe interim, been obliged to refund tothe taxpayer company – unless thelatter, in the meantime, goesinsolvent.

The moral of the story (which is asrelevant to taxpayers as to SARS) isthat the procedural aspects of anappeal to the High Court (and indeedto the Tax Court) must be strictlyadhered to, and that non-compliance will not necessarily be condoned bythe court even if the party in defaulthas a good prospect of success.

Although SARS hadexcellent prospects ofsuccess in its appeal, thisfactor alone did not justifyfailure to abide by the timelimits and other proceduralsteps which the rules ofcourt require to be followedin an appeal.

SARS publishes STC guideA Comprehensive Guide to STC has recently beenreleased by SARS, dealing with all aspects of thishighly complex area of our tax law. Notwithstanding the announcements in the Budget Speech in February thatSTC is scheduled to be replaced by a withholding tax,this publication is a welcome and useful addition toSARS’s library of interpretation. It may be expectedthat STC issues may still arise in the future from auditinquiries even after STC may have been consigned tohistory. The guide may be downloaded from the SARSwebsite: sars.gov.za.

Tax write-off regulationspublishedIn the February issue of Synopsis we discussed the draftregulations relating to the writing-off of tax debts by SARS. The regulations have now been published in GovernmentGazette No. 29788 of 13 April 2007.

Increase in jurisdiction for TaxBoardIn terms of section 83A of the Income Tax Act andsection, and section 33A of the Value-Added Tax Act, any appeal must be referred to the Tax Board if the amount indispute does not exceed an amount fixed by the Ministerby Notice in the Gazette or if SARS and the taxpayerotherwise agree.

The Minister has recently increased the jurisdictionallimit of the Tax Board to R500 000, in terms ofGovernment Gazette No. 29742 dated 28 March 2007.

A guide to the newtax regime forrecreational clubsPlease visit our website pwc.com/za and go to "Of special interest"where you will find the link to

download a copy of the PricewaterhouseCoopers guide on the new tax regime for recreational clubs. Sectionsinclude:

• Many clubs now engage in business activities• Trading income from providing amenities to members• The scope of the exemption• The roll-over of capital gains• The compliance burden imposed by the new tax rules• The administrative and accounting compliance burden• Will club subscriptions have to rise?• Consequences of non-compliance• The way forward.

• Editor: Ian Wilson • Written by R C (Bob) Williams • Sub-editor and lay out: Carol Penny Tax Services Johannesburg

• Dis tri bu tion: Elizabeth Ndlangamandla •Tel (011) 797-5835 • Fax (011) 209-5835 • www.pwc.com/za

This publication is provided by PricewaterhouseCoopers Inc. for information only, and does not constitute the provision of professional advice of any kind. The information

provided herein should not be used as a substitute for consultation with professional advisers. Before making any decision or taking any action, you should consult a

professional adviser who has been provided with all the pertinent facts relevant to your particular situation. No responsibility for loss occasioned to any person acting or

refraining from action as a result of any material in this publication can be accepted by the author, copyright owner or publisher.

© 2007 PricewaterhouseCoopers Inc. All rights reserved. PricewaterhouseCoopers refers to the network of member firms of PricewaterhouseCoopers International Limited,

each of which is a separate and independent legal entity. PricewaterhouseCoopers Inc is an authorised financial services provider.

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