Assignment 1 Semester 2 2026
Unique number:
Due date: 19 August 2026
QUESTION 1: DEDUCTIONS
1.1 Expenditure can only be deducted under section 11(a) if the taxpayer
carries on trade.
True.
Section 11(a) of the Income Tax Act allows a deduction for expenditure and losses
actually incurred in the production of income, provided that the income comes from
carrying on a trade.1 Section 23(g) strengthens this requirement by preventing a
taxpayer from deducting expenditure that was not incurred for purposes of that
trade.1 The general deduction formula therefore requires a clear connection between
the expense, the taxpayer's trade and the production of income. The study guide
similarly explains that only expenditure incurred for purposes of a taxpayer's trade
, QUESTION 1: DEDUCTIONS
1.1 Expenditure can only be deducted under section 11(a) if the taxpayer
carries on trade.
True.
Section 11(a) of the Income Tax Act allows a deduction for expenditure and losses
actually incurred in the production of income, provided that the income comes from
carrying on a trade.1 Section 23(g) strengthens this requirement by preventing a
taxpayer from deducting expenditure that was not incurred for purposes of that
trade.2 The general deduction formula therefore requires a clear connection between
the expense, the taxpayer's trade and the production of income. The study guide
similarly explains that only expenditure incurred for purposes of a taxpayer's trade
may be deducted from income earned through that trade.3
1.2 Because employment is not a trade, no expenditure relating to employment
may be deducted under section 11(a).
False.
Employment is included within the wide meaning of trade under the Income Tax Act,
meaning that an employee can in principle be regarded as carrying on a trade for
income tax purposes.4 The main difficulty is not that employment falls outside trade,
but that section 23(m) places special limits on expenses that an employee or office
holder may deduct from employment income.5 Certain deductions can therefore still
be claimed where the Act specifically allows them, which means that employment-
related deductions are restricted rather than completely prohibited. SARS also
confirms that employees may claim certain qualifying deductions, including particular
legal costs, wear and tear and qualifying bad or doubtful debts.
1.3 A taxpayer whose only income is derived from employment can claim all
expenses incurred as a section 11(a) deduction.
1
Income Tax Act 58 of 1962 s 11(a).
2
Income Tax Act 58 of 1962 s 23(g).
3
University of South Africa, LML4804 Income Tax Law: Tutorial Letter 501/2/2023 (Unisa 2023) 34.
4
Income Tax Act 58 of 1962 s 1, definition of „trade‟.
5
Income Tax Act 58 of 1962 s 23(m).