The extinction of 'intra-group' debt : a case study analysis of the interaction between sections 8(4)(m) and 20(1)(a)(ii) and the applicability of the eighth schedule to the Income Tax Act 58 of 1962
Master Thesis
2010
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University of Cape Town
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Abstract
A group finance company (or treasury company) is often established within a group of companies on the basis that all excess cash of the group will be deposited with that finance company and said finance company will act as a moneylender to the rest of the group. It is however not only the finance company that acts as a lender; loan accounts commonly exist between various companies within a group. These loans are required for a number of reasons, ranging from capital to operating requirements. It also happens that goods are supplied or services rendered between companies within the group which are not immediately paid for but remain outstanding on the loan account.
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Huisamer, D. 2010. The extinction of 'intra-group' debt : a case study analysis of the interaction between sections 8(4)(m) and 20(1)(a)(ii) and the applicability of the eighth schedule to the Income Tax Act 58 of 1962. University of Cape Town.