SAICA National Tax Committee’s submission on the proposed changes to the definition of “contributed tax capital” (CTC) as contained in the second batch of the Draft Taxation Laws Amendment Bill of 2021 (DTLAB).

This submission contains SAICA’s comment on the proposed changes to the definition of CTC as contained in the second batch of the DTLAB. It notes that the proposed amendment will effectively prevent targeted share buy-backs from taking place in which CTC is sought to be returned to a particular shareholder. This will in certain circumstances have a negative unintended impact on taxpayers and the proposed changes also have further possible anomalies when read with paragraph 43A of the Eighth Schedule.