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In this case, SARS relied on section 103(2) to disallow the set off of ABC (Pty) Ltd's ("ABC's") assessed loss against income derived by ABC in respect of its 2005 to 2008 years of assessment.

This issue of ENS' tax in brief provides a comprehensive snapshot of recent South African tax developments, including significant High Court judgments on SARS appeals and enforcement orders, new SARS publications on documentary proof requirements and the Advance Pricing Agreement programme, and multiple customs and excise tariff amendments affecting various imported goods. The brief also covers important international developments from the OECD regarding the Global Minimum Tax implementation and corporate t