An Analysis of the Term Actually Incurred in Section 11(a) of Income Tax Action

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An Analysis of the Term Actually Incurred in Section 11(a) of Income Tax Action

Act No. 58 of 1962

1.SYNOPSIS

Generally Accepted Accounting Practice includes statement AC000: Framework for

the preparation and presentation of financial statements. This sets out broad

and definitive rules governing the recognition of liabilities and income and

expenditure in financial statements. Specifically the following paragraphs need

to be considered:

Recognition of liabilities:

91. A liability is recognised in the balance sheet when it is probable

that an outflow of resources embodying economic benefits will

result from the settlement of a present obligation and the amount

at which the settlement will take place can be measured reliably...

Recognition of expenses:

94. Expenses are recognised in the income statement when a decrease in

future economic benefits related to a decrease in an asset or

an increase of a liability has arisen that can be measured

reliably. This means in effect that recognition of expenses

occurs simultaneously with the recognition of an increase

or a decrease in assets

95. Expenses are recognised in the income statement on the basis

of a direct association between the costs incurred and the and the

earning of specific items of income. This process, commonly

referred to as the matching of costs with revenues, involves the

simultaneous or combined recognition of revenues and expenses that

result directly and jointly from the same transaction or other

events;

The fisc takes little notice of these rules when it comes to the recognition of

expenditure for the purposes of taxation. It is the part of these rules that

govern the general deduction provision that this report will examine.

Section 11(a) of the South African Income Tax Act No. 58 of 1962 (as amended)

reads as follows:

11. General deductions allowed in the determination of taxable income.-

For the purpose of determining the taxable income derived by any

person from the carrying on of any trade within the Republic, there

shall be allowed as deductions from the income of such person so

derived-

(a) expenditure and losses actually incurred in the Republic in the

production of the income, provided such expenditure and losses

are not of a capital nature.

The section defines the conditions that must be met for expenditure and losses

to be allowed as deductions from income. The expenditure or losses must have

been: Actu

ssme

nt

In the Republic of South Africa.

In the production of the income.

Such expenditure or losses must not be of a capital nature.

The section has to be read together with s23(g)

23. Deductions not allowed in the determination of taxable income.-

No deductions shall be made in respect of any moneys, claimed

as a deduction from trade, to the extent to which such monies

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