Section 10(1)(cO) of ITA

(cO)  the receipts and accruals of any recreational club approved by the Commissioner in terms of section 30A, to the extent that the receipts and accruals are derived –

  

(i)      in the form of membership fees or subscriptions paid by its members;

(ii)     from any business undertaking or trading activity that –

(aa)   is integral and directly related to the provision of social and recreational amenities or facilities for the members of that club;


(bb)   is carried out on a basis substantially the whole of which is directed towards the recovery of cost; and


(cc)    does not result in unfair competition in relation to taxable entities;


(iii)    from any fundraising activities of that club, which are of an occasional nature and undertaken substantially with assistance on a voluntary basis without compensation; and

(iv)    from any other source and do not in total exceed the greater of –

(aa)  five per cent of the total membership fees and subscriptions due and payable by its members during the relevant year of assessment; or

(bb)   R120 000;