Question
Scenario 2: SA-P (Pty) Ltd (SA-P) is a local incorporated company and manufactures various plastic containers in Gauteng, South Africa. The companys manufacturing process is
Scenario 2: SA-P (Pty) Ltd (SA-P) is a local incorporated company and manufactures various plastic containers in Gauteng, South Africa. The companys manufacturing process is recognised by the Commissioner as a qualifying process of manufacture. The company is not a small business corporation as defined in the Income Tax Act 58 of 1962. SA-Ps year of assessment ends on the last day of March and it is registered as a category A, value- added tax (VAT) vendor, making only taxable supplies. All transactions are conducted with registered VAT vendors, unless specifically stated otherwise. Where necessary, SA-P obtained valid tax invoices and the required documentation for all its transactions. On 1 September 2021, SA-P purchased a vacant piece of land for R880 000. SA-P plans to use this land to erect a new factory for its manufacturing business. Its plan is to erect the factory during the next year of assessment and to start using it on 1 March 2022, if the building process goes according to plan. During February 2022, SA-P received an offer to purchase the vacant land for R1 500 000 from Developers (Pty) Ltd. SA-P does not usually trade in property and all the property owned by the company is held as investment property. REQUIRED SA-P approached you as a tax consultant to advise the company what the normal tax implications will be if the company decided to sell the vacant piece of land to Developers (Pty) Ltd before the end of the current (2022) year of assessment. In your advice to SA-P (Pty) Ltd, you need to consider whether the R1 500 000 offer to purchase will be regarded as gross income as defined in the Income Tax Act for the 2022 year of assessment if the offer is accepted
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