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The following are two separate scenarios. All the parties involved are residents of South Africa: Scenario 1 Lamas Ltd owns all the shares of Marsi
The following are two separate scenarios. All the parties involved are residents of South Africa: Scenario 1 Lamas Ltd owns all the shares of Marsi Ltd and Neymar Ltd. Marsi Ltd sells manufacturing equipment that is used to produce soccer balls to Neymar Ltd on a loan account. Neymar Ltd will also use the equipment to manufacture balls. Scenario 2 SA Properties Ltd owns all the shares of Tricore Ltd and Footjoy Ltd. Tricore Ltd sells a property that it held as trading stock to Footjoy Ltd on a loan account. Footjoy Ltd will use the property as a capital asset. REQUIRED: Discuss whether the two transactions are intra-group transactions as contemplated in section 45 of the Income Tax Act
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