Transaction $1$:

On $1$ September $2023,$ Sm resort granted a loan of R$200000$ to Ms$.$ Sam by virtue of her shareholding. The loan bears interest at $5\%$ per annum. You can assume that the official interest rate was $8\%$ for the entire $2024$ year of assessment.

Transaction $2$:

On $1$ January $2024,$ Sm Resort distributed a building with a market value of R$3200$

$000$ as a dividend in specie to Ms$.$ Sam $($dividend$$ as defined in section $1(1)$ of the

Act$).$ The building was acquired by Sm Resorts for R$2000000$ on $15$ December $2010.$

The building did not qualify for any capital allowance and Ms$.$ Sam will also utilise the building in such a manner that it will not qualify for any capital allowance. You may assume that Sm Resorts had no other disposals during its $2024$ year of assessment. Sm Resorts also had no assessed capital loss in respect of its $2023$ year of assessment.

Discuss, with calculations, all the Dividends tax and Capital gains tax consequences relating to Sm Resort$$s $2024$ year of assessment for Transaction $1$ and Transaction $2$