Who (or what) emerged as king? An analysis of the Coronation-case:
The Constitution Court (“the Court”) had the final word on the Coronation Investment Management SA (Proprietary) Limited (“Coronation SA”) v Commissioner for the South African Revenue Service (“SARS”) case on 21 June 2024. The matter dealt with the Income Tax Act’s section 9D-exemption in relating to foreign subsidiaries of South African-based companies, i.e. controlled foreign […]