Company distributions in perspective

Transcription

1 Company distributions in perspective Herman Viviers 22 September 2015

2 Disclaimer Nothing in this presentation should be construed as constituting tax advice or a tax opinion. An expert should be consulted for advice based on the facts and circumstances of each transaction/case. Even though great care has been taken to ensure the accuracy of the material, the presenters do not accept any responsibility for consequences of decisions taken based on the material. It remains your own responsibility to consult the relevant primary resources when taking a decision.

3 SESSION OVERVIEW TYPES OF COMPANY DISTRIBUTIONS? BASICS OF DIVIDENDS TAX Background: Why the need to replace STC with Dividends Tax regime? Shift in liability & administrative provisions What is a dividend? (Normal Tax vs Dividends Tax) Deemed dividends Dividends exempt from Dividends Tax The bigger picture of dividends (all tax implications) RETURN OF CAPITAL DISTRIBUTIONS (on/after 1 April 2012) DISTRIBUTIONS DURING WINDING-UP, LIQUIDATION OR DEREGISTRATION SHARE BUY-BACKS AND THE DISTRIBUTION OF SHARES FOR NO CONSIDERATION DIVIDEND-STRIPPING SCHEMES

4 COMPANY DISTRIBUTIONS A distribution made by a co (under normal circumstances, during liquidation or a re-purchase of shares) is either: Dividend or Return of capital (from contributed tax capital) Subject to: Normal tax Dividends tax VAT Subject to CGT How will the holder of shares know whether the distribution received on its shareholding constitutes a distribution from retained earnings? or contributed tax capital? par 76(4), 8 th Schedule

5 BACKGROUND STC system: (Dividend declared Dividend received) x 10% Why the need for Dividends Tax Regime? From what are dividends declared and paid? What types of dividends do exist? Timeline: Jan April 2012 Minister of Finance announces that the definition of a dividend will be simplified. New definition for dividend introduced. 10% is replaced by the new Dividends Tax on a co level Tax on a H/S level

6 Dividend (either in cash or in specie) Normal Tax Dividends Tax Dividend (s 1) Foreign dividend (s 1) Dividend (s 64D) Means any amount transferred or applied by a co that is a resident for the benefit or on behalf of any person in respect of any share in that company, whether that amount is transferred or applied- (a) by way of a distribution made by; or (b) as consideration for the acquisition of any share in, that company, but does not include any amount so transferred or applied- (i) results in a reduction of contributed tax capital of the company; or (ii) constitutes shares in the company; or (iii) constitutes an acquisition by the company of its own securities by way of a general repurchase of securities as contemplated in subparagraph (b) of paragraph 5.67(B) of section 5 of the JSE Limited Listings Requirements

7 Dividend (either in cash or in specie) Normal Tax Dividends Tax Dividend (s 1) Foreign dividend (s 1) Dividend (s 64D) Means any amount that is paid or payable by a foreign company in respect of any share in that foreign company where the amount is treated as a dividend or similar payment by that foreign company for the purposes of the laws relating to- (a) tax on income on companies of the country in which that foreign company has its place of effective management; or (b) companies of the country in which that foreign company is incorporated, formed or established, where the country in which that foreign co has its place of effective management does not have applicable laws relating to tax on income, but does not include any amount so paid or payable that- (i) constitutes a redemption of a participatory interest in an arrangement or scheme contemplated in par (e)(ii) of the definition of "company"; or (iii) constitutes a share in that foreign company.

8 Dividend (either in cash or in specie) Normal Tax Dividends Tax Dividend (s 1) Foreign dividend (s 1) Dividend (s 64D) Means any dividend or foreign dividend as defined in section 1 that is- (a) paid by a company that is a resident; or (b) paid by a foreign company- (i) if the share in respect of which that foreign dividend is paid is a listed share and (ii) to the extent that the foreign dividend does not consist of a distribution of an asset in specie. Therefore, a foreign dividend could only be subject to Dividends Tax if: the share is listed on the JSE and it is paid in cash

9 Where a dividend is declared/paid, 2 parties are involved: Co / CC Distribution of a dividend = cash / in specie Person (NP, Co, CC, Trust etc.) which holds shares ACCOUNTING TREATMENT? Distribution in cash Dr Equity (Retained earnings) Cr Bank Distribution in cash Dr Bank Cr Dividends received (SoP/L) Distribution in specie Dr Equity (Retained earnings) Cr Asset / Trading stock Distribution in specie Dr Asset / Trading stock Cr Dividend received (SoP/L)

10 Where a dividend is declared/paid, 2 parties are involved: Co / CC Distribution of a dividend = cash / in specie TAX TREATMENT? Person (NP, Co, CC, Trust etc.) that holds shares Distribution in cash No s 11(a) deduction not in the production of income Paid from after tax profits Retains on behalf of H/S and pays over to the SARS. Distribution in specie If distribution = capital asset Recoupment s 8(4)(k) + CGT par 11(1)(e) and par 75 Proceeds = MV If distribution = TS Recoupment s MV Distribution in cash Gross income def. s 1, par (k) Source? Refer s 9(2)(a) Less exemptions: Local dividend s 10(1)(k); Foreign dividend s 10B Distribution in specie If distribution = capital asset Par 75: Deemed to MV Possible wear-and-tear, s 11(e) If distribution = TS, s MV GI, par (k) and exemption

11 EXEMPTIONS FROM DT FOR DIVIDENDS IN SPECIE [s 64F] Is exempt from DT if the beneficial owner = A resident company Government, Provincial administration or Municipality PBO Institution/board/body with the sole or principle objective of: Scientific/technical/industrial research Goods supplied/services rendered to government/general public carry on activities promoting commerce/industry/agriculture. PF, ProvF, RAF, friendly society or medical scheme CSIR, SAIDC, SA National Roads Agency H/S in a Micro Business (6 th Schedule) iro dividends R per yoa Non- resident and the dividend was declared by non-resident co listed on the JSE. CIS in securities Any person to the extent that the dividend constitutes income of that person Any person to the extent that the dividend was subject to STC A NP iro a dividend paid iro a section 12T tax free investment

12 EXEMPTIONS FROM DT FOR DIVIDENDS IN SPECIE [s 64FA] Is exempt from DT if" a) the person to whom the payment is made submitted to the company by the date of payment of the dividend: i) a declaration by the B/O that the dividend in specie would have been exempt ito s 64F if it was not a dividend in specie, AND ii) a written undertaking that should circumstances change affecting the exemption status of the B/O, the company will be informed of the fact. b) The B/O forms part of the same group of companies (as defined in s 41) If no exemption is applicable, DT will be levied at 15%. Reduced rate? DTA?

13 DIVIDENDS TAX = WITHHOLDING TAX DT is withheld on behalf of the beneficial owner (B/O) (except with a dividend in specie). Who withholds the DT on behalf of the beneficial owner? Either the co which declares and pays the dividend Or a regulated intermediary But not both!!! Scenarios: The indicates the flow/distribution of dividends. Co B/O Co Regulated intermediary B/O Co Regulated intermediary Regulated intermediary B/O

14 Regulated intermediary? [Defined in s64d] Regulated intermediary Central securities depository participant Authorised user Approved nominee Nominated person holding investments on behalf of clients Portfolio of CIS in securities Transfer secretary ( NP) As described and referred to in s 32 of Financial Markets Act s 1 of Financial Markets Act s 76(3) of Financial Markets Act Codes of conduct for Administrative & Discretionary Financial Service Providers CIS = collective investment scheme As approved by the Commissioner

15 Rebate for foreign taxes on dividends [s 64N] Why would the SARS allow a rebate? A beneficial owner (resident) can find himself in the unfair position where the dividend on his foreign share investment is taxed two times, namely: SA tax in SA foreign tax in a foreign country. In order to compensate for the double tax effect, a rebate is granted in SA (only if the beneficial owner (B/O) is a resident!) But is a foreign dividend subject to DT? Yes, if the share is listed on the JSE & the dividend in specie. What is the amount of the s 64N rebate? Rebate = foreign tax paid (but only to the extent that it does not exceed the DT paid in SA). The foreign tax would be in a foreign currency. How must it be converted to R in order to compare it to the SA tax in R? Convert to the ruling exchange rate on the date paid. [s 64N(4) refers in effect back to s 64E(5)].

16 VAT consequences of declaring a 'Dividend in specie': No consideration is payable by the beneficial owner in return for the dividend. Value of the supply = Rnil Section 10(23) of the VAT Act. BUT: If beneficial is a connected person who cannot claim full input VAT or only a portion of the input VAT Section 10(4) of the VAT Act will be applicable Value of the supply = open market value Output 100% TS asset in specie No input VAT or < 95% TS Co. A Connected persons 20% shares in Co. A Thus, output VAT is charged on MV, while input VAT is claimed on the actual consideration which is Rnil.

17 EXAMPLE 1: Distribution of dividend in specie Co. A and Co. B (both vendors) is connected persons in relation to each other. Co. A distributes an asset as a dividend in specie to Co. B. The market value of the asset is R , while it had a original cost of R (excluding VAT) and a tax value of R What is the tax implications for both Co A & Co. B? VAT consequences Co. B will claim full VAT input (100%), thus s 10(4) not applicable. Value of supply = Rnil [s 10(23)] Co. A = No output VAT & Co. B no input VAT Normal tax consequences Co. A: s 8(4)(k) recoupment: (R ltd R ) R = R (include in GI) CGT: [R (par 75) R60 000] less R = R x 66.6% = R6 660 Co. B: Inclusion in gross income, par (k): R Exemption, section 10(1)(k): (R ) Base cost of asset for CGT purposes = R [par 75, Eighth Schedule] Dividends tax Exempt ito s 64FA if declaration and written undertaking is in place.

18 Section 64E(4): DEEMED DIVIDENDS? Loan granted by company due to shares held Section 24BA(3)(b): Asset for shares where: MV of shares before > MV of asset after Section 9H(3)(c)(iii): Resident Co cease to be a resident Section 57: Disposal by a company under a donation at the instance of any person

19 Requirements of s 64E(4): The loan must be due TO the co and not BY the co. The H/S owing the money may not be a co (including a CC). Thus, the H/S may be a NP, sole proprietor, trust etc. The reason why the loan was granted must be because he/she is a H/S. The H/S must be a resident. The H/S must be a connected person irt the company (eg. Scenario A) OR the person to who the money is borrowed must be a connected person irt a H/S which is a connected person irt the company (e.g. Scenario B). Scenario A: Scenario B: Co Co 20% of ES or VR Loan granted Loan granted 20% of ES or VR Resident Resident Beneficiary Trust

20 What is the AMOUNT of the deemed dividend? [s 64E(4)(b)] Deemed Dividend = Market related interest on the loan Less Actual interest payable on the loan (if any) Official interest rate (par 1, 7 th Schedule) Currently: 6% (from 24 July 2015, thus effective from 1 Aug 2015) s 64E(4)(d) What if the actual interest market related interest? When will the deemed dividend be paid/payable? s 64E(4)(c)

21 s 24BA Asset acquired as consideration for shares issued Any person asset shares Co If this consideration in the form of shares is not a fair consideration that would have applied between independent persons dealing at arm s length, then s 24BA is applicable. Note: par 11(2)(b) of the 8 th Schedule determines that the issue of shares disposal for CGT purposes, but if: MV of asset before > MV of shares after When is s 24BA not applicable? [s 24BA(4)] Excess = CG in the hands of Co and Excess applied to reduce the par 20/s 11(a), 22(1), 22(2) cost of the shares in the person's hands MV of asset before < MV of shares after Deemed dividend in specie paid by the Co on the date the shares were issued to the person.

22 EXAMPLE:ASSET FOR SHARE Asset = R800 Mr. A Shares = R500 Co X Tax consequences for Co. X The difference of R300 is a capital gain ito s 24BA to be recognised by Co. X. Co. X deemed to have acquired an asset at R500 (the market value of the shares immediately after the acquisition of the shares) [s 40CA] Tax consequences for Mr. A Acquire shares at the value of R800 But, the value of the share must be reduced with the value of the CG recognised by Co. X Therefore: R800 R300 = R500

23 EXAMPLE:ASSET FOR SHARE Deemed dividend in specie Asset = R500 Mr. A Shares = R800 Co X Tax consequences for Co. X The difference of R300 = deemed dividend in specie declared by Co. X. Deemed to be declared on the date the shares were issued. Onus of liability to pay Dividends Tax is on Co. X (R300 x 15% = R45) Co. X deemed to have acquired an asset at R800 (the market value of the shares immediately after the acquisition of the shares) [s 40CA] Tax consequences for Mr. A Acquire shares at the value of R500

24 s 40CA KL3 Assets acquired in return for shares or debt issued asset Any Co Scenario (a): person shares At what value will the Co acquire the asset? Deemed as if the Co acquired the asset at the market value of the shares immediately after the acquisition of the shares. Scenario (b): Any person asset Debt: money borrowed to Co At what value will the Co acquire the asset? Deemed as if the Co incurred an expense equal to the amount of the debt (issued to the "person"). This debt amount represents the cost of the asset.

25 ASSET-FOR-SHARE TRANSACTIONS SUMMARY: s 24BA s 42 s 40CA If the value of the shares is not a fair consideration in return for the asset, then s 24BA applies. If the requirements of s 42 are met it will apply automatically, unless both parties agree in writing that s 42 should not apply. Both s 24BA and s 42 could be applied to the same 'asset-for-share' transaction at the same time!!!! [see section 41(2)] s 24BA affects the company that issues the shares: OR capital gain, OR dividend in specie. If s 24BA results in a capital gain to be recognised, the person that acquires the shares must make an adjustment to the base cost of the shares ito s 24BA s 40CA will only apply if s 42 does not apply. Thus, s 40CA is subject to s 42 s 40CA only affects the co receiving the asset in return for the shares issued. s 40CA determines the value of the asset in the hands of the co

26 Section 9H(3)(c): COMPANY CEASES TO BE A RESIDENT When is a company a resident in SA? [s 1, definition of resident] if incorporated, established or formed in the Republic; or has its place of effective management in SA Tax consequences if "company cease to be a resident": yoa deemed to end date immediately prior to "cease to be a resident" next succeeding yoa deemed to commence on day that co cease to be a resident Co is deemed to have declared and paid a dividend consisting solely of an asset in specie = Sum of MV of all the shares in that company Less: sum of the contributed tax capital of all classes of shares in the co

27 Section 57: Disposals by companies under donations at the instance of any person EXAMPLE: Mr A holds 60% and Mr Y 40% of the shares in Co X. Mr A instructs that Co X to donate a computer to his son. What is the tax consequences? Mr. A Mr. B 60% 40% Co X Mr. A's son Who makes the donation? What is the deciding factor? What type of property will fall within the scope of section 57? What are the dividends tax consequences?

28 COMPANY DISTRIBUTIONS A distribution made by a co (under normal circumstances, during liquidation or a re-purchase of shares) is either: Dividend Return of capital (from contributed tax capital) Subject to: Normal tax Dividends tax VAT or Subject to CGT How will the holder of shares know whether the distribution received on its shareholding constitutes a distribution from retained earnings? or contributed tax capital? par 76(4), 8 th Schedule

29 Par 76 to 78: Capital distributions on H/S level Important concepts (effective from 1 April 2012): share [s 1]: - In relation to any company - any unit into which the proprietary interest in that company is divided Date of distribution [par 74]: Specific rules for the following scenario s: Scenario Distribution made by a listed company that is not a distribution of an asset in specie Date of distribution? = the date on which the distribution is paid. Distribution made by a non-listed company that is not a distribution of an asset in specie Distribution consists of a distribution of an asset in specie = the earlier of: date paid or when it becomes due and payable = the earlier of: date paid or when it becomes due and payable

30 return of capital (roc) [s 1]: - Any amount (cash and/or assets) - transferred by a resident company - to a person holding a share in that company - to the extent that it results in a reduction of contributed tax capital - Excluding: an amount that constitutes- shares in the company; or consideration for the acquisition of its own shares (s 5: JSE LR ) contributed tax capital [s 1]: - determined per class of shares (not per share!) - The co making the distribution elects to make this kind of distribution. - If it is elected the H/S should be notified in writing [required by par 76(4)]. - dividend! (H/S receives something back, given to the co previously). There is a LIMITATION on distributions from ctc made to a H/S, namely: Total amount of ctc attributable to that class immediately before the transfer X Number of shares of that class held by the S/H Total number of shares of that class

31 What is contributed tax capital? 2 Scenario s: a) Non-resident co becomes a RSA resident on/after 1 Jan 2011 The following occurs on/after the co became a resident: A and C A MV of specific class of shares on day before co became a resident. B Co issues shares of that specific class and receives consideration for it. C The co transfers contributed tax capital to any person holding a share in that specific class of shares AND on the date that this transfer takes place it has been determined by the directors of the company (or by a person or body with comparable authority) to be an amount so transferred. B contributed tax capital = A + B - C

32 b) Any other Co. B 1 Jan 2011 A C and D A Stated capital OR SC and SP immediately before 1 Jan B Part of A as would have constituted a dividend, had it been distributed immediately before 1 Jan C Consideration received by the Co for issuing the specific class of shares on/after 1 Jan 2011 D Part of contributed tax capital that co transferred on/after 1 Jan 2011 to any person holding a share in that class of shares of that co AND on the date that this transfer takes place it has been determined by the directors of the company (or by a person or body with comparable authority) to be an amount so transferred. contributed tax capital = A B + C - D

33 Co-distributions from 1 April 2012 [par 74 to 78] Par 75: Capital distributions on Co level = distribution in specie Co distributes an asset to a person holding a share in that company Co must notify the S/H in writing to what extent the distribution = return of capital [par 76(4)] Par 11(1)(e) disposal = distribution of an asset by a co to a H/S Co DEEMED to dispose of proceeds = MV of asset as on date of distribution Proceeds must be reduced by the recoupment [par 35(3)(a)]: s 22(8) if asset = TS s 8(4)(k) if asset = depreciable asset Co realises: - CG or - CL Are Co and H/S connected persons? If yes Par 39 CL will be clogged H/S deemed to acquire the base cost = the same MV [see par 76(3)], but only for future CGT purposes!

34 CGT implications for a "return of capital" (roc) distribution [Par 76B]: Is there a full (100%) disposal of the share on/after 1 April 2012? Yes No Proceeds = roc received/accrued Less: Base cost =capital gain/loss Adjust the redetermined base cost of the share with the roc received. How? Reduce the base cost with amount of roc received/ accrued. Base cost? Deemed to Base cost = the same MV* Less notional CG Plus notional CL [Par 76B(1)(ii)] Is the share a pre-valuation date asset? Yes Re-determine: 1. Acquisition date 2. Base cost Acquisition date? Deemed disposal (100%) immediately before roc : Proceeds = MV* of share at that time [Par 76B(1)(i)] Less: Base cost = VDV par 26/27 = "notional" CG/CL No Par 76B(2): No deemed disposal. Only reduce the base cost with amount of roc received/ accrued. If: roc > base cost, recognise excess as a CG received. [Par 76B(3)]

35 EXAMPLE 1: "roc" on shares acquired before 1 October 2001 Mr. A holds all the Shares in Co. X. The base cost of the shares acquired in 2000 by Mr. A is R150. Co. X makes a return of capital distribution to Mr. A on 31 May 2015, but Mr. A does not fully dispose over the shares. REQUIRED: Determine the CGT consequences for Mr. A if: Co. X makes a return of capital distribution of R100 to Mr. A. when the market value of the share is R300 while the valuation date value as calculated on 31 May 2015 is R200. SOLUTION: Deemed disposal immediately before "roc" is received: Proceeds (MV* at that date) Less: Base cost (pre-valuation date asset. Thus, VDV as given) "Notional" capital gain R300 (R200) R100 Deemed to be re-acquired at the same MV* Less: "Notional" capital gain Base cost "brought up to date "New acquisition date: 31 May 2015" Adjust with the "roc" received New established base cost R300 (R100) R200 (R100) R100_

36 EXAMPLE 2: "roc" on shares acquired after 1 October 2001 Mr. A holds all the shares in Co. X. The base cost of the shares acquired in 2003 by Mr. A is R200. Co. X makes a return of capital distribution to Mr. A on 31 May 2015, but Mr. A does not fully dispose over the shares. REQUIRED: Determine the CGT consequences for Mr. A if: a) Co. X makes a return of capital distribution of R150 to Mr. A. b) Co. X makes a return of capital distribution of R500 to Mr. A. SOLUTION: a) Adjust the base cost as follows: Base cost R200 Less: "roc" (R150) New base cost R50_ SOLUTION: b) Adjust the base cost as follows: Base cost R200 Less: "roc" R500 ltd to (R200) New base cost Rnil Capital gain Excess (R500 R200) R300

37 Par 77: Distributions due to winding-up, liquidation or deregistration When a co liquidates or deregisters a H/S is deemed to dispose of its shares at the earlier of: date of dissolution/deregistration; or in the case of winding-up or liquidation, the date that liquidator declares in writing that no further distributions will be made. Any roc distribution received AFTER the above deemed disposals will qualify as a capital distribution and the H/S must recognise a CG. EXAMPLE: LIQUIDATION DISTRIBUTION (Source: Silke 2015) Mr. A owns 20% shares in ABC Ltd with a base cost of R June 2014: ABC Ltd is placed in liquidation. 20 October 2014: Liquidator distributes R100 'return of capital' to Mr. A indicating that after this, creditors will be settled and that holders of shares should not expect any further distributions. 10 April 2015: Hidden assets of ABC Ltd is discovered and Mr. A received a further R30 in cash. None of the distributions constitute dividends. SOLUTION: Mr. A will have the following tax consequences: Deemed disposal on 20 October 2014: R100 (Proceeds) R500 (BC) = (R400) CL In 2016 year of assessment: recognise CG of R30 [par 77(2)]

38 Share buy-backs roc in s 1 specifically includes: an amount transferred (to the H/S) as consideration for the acquisition (by the co) of any share (excluding s 5 JSE LR-shares) Consideration for a share buy-back transaction can comprise a dividend and a roc. The roc will trigger CGT in the hands of the H/S. EXAMPLE: BUY-BACK OF SHARES (Source: Silke 2015) Mr. A owns 80% of XYZ Ltd's shares. The base cost of Mr. A's shares is R Mr. A surrenders all his shares in XYZ Ltd for a R distribution. XYZ Ltd notified Mr. A that R of the distribution represents contributed tax capital, while R qualifies as a dividend. Calculate the tax consequences for Mr. A iro the distribution. SOLUTION: Contributed tax capital = CGT consequences (full disposal, after 1 April 2012) R (Proceeds = 'ctc') R (base cost) = (R ) The capital loss will be "clogged" ito par 39 Dividends tax: R x 15% = R Normal tax: R [GI, par (k)] R [s 10(1)(k)] = Rnil

39 Shares issued for no consideration [s 40C] In effect a "capitalisation issue" Example: "Each holder of shares will receive one share for no consideration in respect of every five shares held" The term "capitalisation issue" was replaced with "the distribution of shares for no consideration" from 1 January Section 40C deems the base cost of the shares received by the holder of shares for no consideration to be Rnil. Par 78 of the 8 th Schedule repealed from 1 Jan 2013 and replaced with section 40C.

40 DIVIDEND-STRIPPING SCHEMES 2 Types of schemes: Shares acquired as capital investment Shares acquired as trading stock

41 1. Capital investment: Par 19, Eighth Schedule (from 1 April 2012) Purchase 80% share as investment 80% Dividend declaration 2 Benefits: 1. Exempt dividend 2. Capital loss What are the circumstances? 2 Scenario s: 1. Person disposes of share in CL due to winding-up by the co liquidation/deregistration of co Then: The part of the CL exempt dividend received/accrued within 18 months before/as part of the disposal MUST BE DISREGARDED! 2. Person disposes of share in CL under normal circumstances: The part of the CL extraordinary exempt dividend received/accrued within 18 months before/as part of the disposal MUST BE DISREGARDED! Co

42 Exempt dividend? [par 19(3)(b)] = dividend exempt by s 10(1)(k)(i) OR = foreign dividend exempt by section 10B(2)(a) or (b); AND which is not subject to dividends tax! Extraordinary exempt dividend? [par 19(3)(c)] = Exempt dividends (as defined above) received within 18 months before/part as disposal less (15% of proceeds form the disposal of the shares). If the answer = negative/zero, there is no extraordinary dividend.

43 2. Share dealer: Dividend-stripping Purchase 80% share as trading stock 80% Dividend declaration The loss on the disposal of the shares (now depleted) will be "income" in nature. The expenditure incurred in respect of the acquisition and the maintenance to acquire the shares should be apportioned. Expenditure is incurred to: produce taxable income (the portion of the liquidation distribution that is not a dividend); and to produce exempt income (dividends) The part of the expenditure relating to the exempt dividend will not be allowed as a deduction [s 23(f)] Apportionment formula: CIR v Nemojim (Pty) Ltd Co 2 Benefits: 1. Exempt dividend 2. Loss to be set off against other income

44 Presenter s contact details Herman Viviers herman.viviers@nwu.ac.za

45 Thank you.