Section 10(1)(gG) of ITA

(gG)   any amount received by or accrued to a person as contemplated in subparagraph (ii) or (iii) of paragraph (d) of the definition of “gross income” –

  

(i)      in the case of a policy that is a risk policy with no cash value or surrender value, if the amount of premiums paid in respect of that policy by the employer of the person has been deemed to be a taxable benefit of the person in terms of the Seventh Schedule since the later of-

  

(aa)   the date on which the employer or company contemplated in those subparagraphs became the policyholder of that policy; or

(bb)   1 March 2012,

unless the amount of the premiums paid was deductible by the person in terms of section 11(a);

(ii)     in the case of any other policy, if an amount equal to the aggregate of the amount of any premiums has been included in the income of the person as a taxable benefit in terms of the Seventh Schedule since the date on which the policy was entered into;