EXAM PACK
,TAX2601 – Assessment 1 (Semester 2, 2025)
Question 1 (12 marks)
Issue:
Is the R4 300 000 received from selling the vacant land part of gross income in
Groundhog (Pty) Ltd’s 2025 year of assessment?
Law:
Gross income definition (s1 of the Income Tax Act): includes all amounts
received by or accrued to a taxpayer, excluding amounts of a capital nature.
Whether an amount is capital or revenue depends on case law:
o CIR v Pick ’n Pay Employee Share Purchase Trust – once-off isolated
sales generally capital.
o Elandsheuwel Farming (Edms) Bpk v SBI – intention at acquisition is key.
o Natal Estates Ltd v SIR – if land bought for resale = revenue. If bought for
long-term use in business = capital.
Application:
Groundhog bought land to build a factory (intention = long-term productive use,
i.e. capital asset).
Selling before using it does not change the intention at acquisition
(Elandsheuwel).
Sale was an isolated transaction, not part of its trading stock or normal
business operations (manufacturing).
Proceeds are therefore capital in nature and excluded from gross income.
Conclusion:
The R4 300 000 received is not gross income for 2025 because it is capital in nature.
,Answer (Q1):
The R4 300 000 is excluded from gross income.
Question 2 (12 marks)
Kganya Solutions (Pty) Ltd – Provisional Tax 2025
Step 1: Basic amount rule
Basic amount = taxable income of latest assessed year of assessment,
ending not more than 18 months before the provisional tax year.
For 2025 year:
o 2024 YOA ended 31 March 2024, assessment issued 15 Feb 2025 → not
yet available by first provisional payment (Aug 2024).
o Latest assessed YOA available: 2023 taxable income R2 371 254.
So:
1st provisional tax (Aug 2024): based on 2023 assessed income.
2nd provisional tax (Feb 2025): taxpayer may use either basic amount or
estimate of actual 2025 taxable income (to avoid penalties).
Step 2: Calculate normal tax (2025 corporate rate = 27%)
2025 taxable income (estimate): R3 628 493.
Normal tax = R3 628 493 × 27% = R979 693.
2023 taxable income: R2 371 254 × 27% = R640 239.
Step 3: Provisional payments
1. First payment (due 31 Aug 2024)
o Based on 2023 assessed income (basic amount).
o Tax = R640 239 ÷ 2 = R320 120.
, 2. Second payment (due 28 Feb 2025)
o To avoid underestimation penalties, must cover at least 80% of actual
tax liability (since taxable income > R1 million).
o 80% of R979 693 = R783 754.
o But best to pay full liability: R979 693.
o Less first payment (R320 120) = R659 573 due as second payment.
Final Answer (Q2):
1st provisional tax (31 Aug 2024): R320 120
2nd provisional tax (28 Feb 2025): R659 573
Question 3 (20 marks)
Titan Tech (Pty) Ltd – Tax Computation 2025
Taxable income before adjustments: R3 880 000
1. Trading stock (s22)
Closing stock = lower of cost (R795 000) or market value (R770 000) = R770
000
Adjustment = Opening (R695 000) – Closing (R770 000) = –R75 000 (add back)
2. Employee expenses
Salaries R860 000 → deductible (s11(a)).
Pension contribution R400 000 → deductible under s11(l), limit = greater of:
o 10% of approved remuneration, OR actual contribution.
o Assume fully deductible (since not limited in given info).