Article
Structured Self-insurance: A Win For SARS, But Questions Remain
The Western Cape High Court's recent ruling in C:SARS v Meiring Citrus overturned a Tax Court decision and disallowed a ZAR9.6 million income tax deduction claimed by a citrus farmer for what was marketed as an insurance premium. The judgment raises critical questions about the distinction between genuine insurance and investment arrangements, the burden of proof in prescription cases, and the application of accounting standards to tax deductions. Taxpayers with similar structured self-insurance products sh
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