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Article · 26 June 2019 · Academy of Tax Law

S.Africa: Grounds of assessment held to be unreasonable

… the grounds of assessment were unreasonable in two respects, namely the incorrect utilisation of the Net Asset Value (NAV) methodology and the Commissioner’s valuation of the shares as nil:

This judgment is useful for arguing against unreasonable conduct by Revenue agencies when they issue TP assessments without following the OECD TPGs on methodologies.