EDITORIAL: Coronation vs Sars case is a victory for clarity
Constitutional Court’s ruling over Coronation’s Irish arm is a triumph for fair taxation
In a David-and-Goliath battle, Coronation Fund Managers has emerged victorious against Sars, securing a landmark victory that reverberates far beyond its balance sheet. This isn’t just a win for Coronation; it’s a triumph for fair taxation, clarity and the country’s competitive spirit.
At the heart of the dispute was whether Coronation’s Irish arm qualified as a foreign business establishment, or FBE in taxation parlance, thus exempted from certain taxes. The apex court clarified that an FBE must have genuine economic substance in its foreign jurisdiction — an interpretation that helped Coronation to successfully challenge a hefty R794m tax penalty imposed by Sars. ..
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