Case Law Wrap-Up
Commissioner for SARS v Coronation Investment Management SA (Pty) Ltd (1269/2021) [2023] ZASCA 10 (07 February 2023) The issue before the Supreme Court of Appeal (SCA) in this matter was whether a controlled foreign company (CFC) constituted a foreign business establishment (FBE) as contemplated in the Income Tax Act, No. 58 of 1962 (the ITA).