ARTICLE · 20 APRIL 2021

Tax In Brief | Issue 61

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Below, please find issue 61 of ENSafrica's tax in brief, a snapshot of the latest tax developments in South Africa.

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Below, please find issue 61 of ENSafrica's tax in brief, a snapshot of the latest tax developments in South Africa.

case law

The Supreme Court of Appeal ("SCA") | Commissioner: SARS ("CSARS") v Levi Strauss SA (Pty) Ltd
- The Commissioner for the South African Revenue Service ("SARS") appealed the decision of the Gauteng Division of the High Court, disallowing its origin and transaction value determinations for Levi Strauss South Africa (Pty) Ltd ("Levi SA").
- During the period from 2010 to 2014, Levi SA imported goods from members of the South African Development Community ("SADC"). The arrangements with the suppliers were made by Levi Strauss Asia Pacific Division Pte Ltd ("Levi APD"). The goods were purchased directly from the producers in the SADC, but from 2011 Levi SA purchased the goods from Levi Strauss Global Trading Company Limited ("Levi GTC"), a company incorporated in Hong Kong. In turn, Levi GTC would purchase the goods from the same

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