“International shipping company” definition of section 12Q of ITA

‘international shipping company’ means a company that is a resident that operates one or more South African ships that are utilised in international shipping;

[Definition of “international shipping company” substituted by section 29 of Act 17 of 2017 effective on 18 December 2017]

“International shipping income” definition of section 12Q of ITA

“international shipping income” means the receipts and accruals of a person derived from international shipping mainly from the operation of one or more ships contemplated in paragraph (a) of the definition of “South African ship”;

[Definition of “international shipping income” substituted by section 31 of Act 23 of 2018 effective on 1 April 2019 and applies in respect of years of assessment commencing on or after that date.]

“Intra-group transaction” definition of section 45 of ITA

(1)     For the purposes of this section-

 

‘intra-group transaction’ means any transaction-

 

(a)

 

(i)      in terms of which any asset is disposed of by one company (hereinafter referred to as the ‘transferor company’) to another company that is a resident (hereinafter referred to as the ‘transferee company’) and both companies form part of the same group of companies as at the end of the day of that transaction; and

 

(ii)     as a result of which that transferee company acquires that asset from that transferor company-

 

(aa)    as a capital asset, where that transferor company holds it as a capital asset; or

 

(bb)   as trading stock, where that transferor company holds it as trading stock; or

 

(b)

  

(i)      in terms of which any asset that constitutes an equity share held by a transferor company as a capital asset in a foreign company is disposed of by that transferor company to a transferee company in exchange for the issue of debt or shares other than equity shares by that transferee company;

  

(ii)     as a result of which that transferee company acquires that asset from that transferor company as a capital asset; and

 

(iii)    if, immediately before and as at the end of the day of that transaction-

 

(aa)   that transferor company and that transferee company form part of the same group of companies (as defined in section 1);

 

(bb)   that transferor company is a resident or is a controlled foreign company in relation to one or more residents that form part of that group of companies; and

 

(cc)   that transferee company is a resident or is a controlled foreign company in relation to one or more residents that form part of that group of companies.

“Intrinsic value” definition of section 24I of ITA

“intrinsic value”, in relation to a foreign currency option contract, means the value for the holder or writer thereof, as the case may be, determined by applying the difference between

 

(a)     the spot rate on translation date or the date on which the foreign currency option contract is realised, as the case may be; and

 

(b)     the option strike rate,

 

to the amount of foreign currency as specified in such foreign currency option contract: Provided that such foreign currency option contract shall have a nil value for the holder or writer thereof if such holder thereof would have sustained a loss had he exercised his right in terms of such foreign currency option contract on such translation date or date realised due to the unfavourable difference between the option strike rate and the spot rate on such translation date or date realised;

“Intrinsic value” definition of section 24L of ITA

(1)     For the purposes of this section

  

“intrinsic value”, in relation to an option contract, means an amount equal to the difference between the market price or value of an asset, index, currency, rate of interest or any other factor, as provided for in the option contract, on the date of acquisition of the option contract and the prearranged price or value provided for in the option contract; and

“Investment income” definition of section 12E of ITA

(b)     ‘investment income’ means-

(i)      any income in the form of dividends, foreign dividends, royalties, rental derived in respect of immovable property, annuities or income of a similar nature;

(ii)     any interest as contemplated in section 24J (other than any interest received by or accrued to any co-operative bank as contemplated in paragraph (a)(ii)(ff)), any amount contemplated in section 24K and any other income which, by the laws of the Republic administered by the Commissioner, is subject to the same treatment as income from money lent; and

(iii)    any proceeds derived from investment or trading in financial instruments (including futures, options and other derivatives), marketable securities or immovable property;

(c)     ………

“Investment income” definition of Sixth Schedule

“investment income” means-

(i)      any income in the form of annuities, dividends, foreign dividends, interest, rental derived in respect of immovable property, royalties, or income of a similar nature; and

[Paragraph (i) substituted by section 68 of Act 23 of 2018 effective on 17 January 2019]

(ii)     any proceeds derived from the disposal of financial instruments;