Overview

Attribution Rules, Deeming Provisions, and Anti-Avoidance measures remain some of the most complex and often misunderstood areas in trust taxation. These provisions are essential for correctly identifying the taxpayer, calculating the appropriate tax liability, and ensuring accurate disclosure in a trust’s Annual Financial Statements.

This technical webinar provides a structured overview of the Attribution Rules found primarily in Section 7 of the Income Tax Act, which take precedence over Sections 25B and 26A. It also covers the attribution of capital gains under Paragraphs 68–72 of the Eighth Schedule. We will clarify how and when benefits—real or deemed—must be calculated and attributed before distributions to beneficiaries are considered. With the help of practical examples, this session will equip attendees with both technical insight and accounting treatment guidance.

Webinar Content

• The rationale behind the development of Attribution Rules
• When to apply Attribution Rules versus Sections 25B and 26A
• Defining “donation,” “settlement,” or “other disposition”
• Identifying the correct taxpayer under Attribution Rules
• Application of Sections 7C and 7D
• Detailed review of each Attribution Rule in Section 7
• Overview of Paragraphs 68–72 of the Eighth Schedule (capital gains attribution)
• Practical examples and computations
• Accounting treatment in Annual Financial Statements
• Disclosure requirements in the Income Tax Return

Competencies Developed

• Understand the legislative purpose and practical application of Attribution Rules
• Determine when and to whom Attribution Rules apply
• Accurately compute taxes under Section 7 and Paragraphs 68–72 of the Eighth Schedule
• Correctly reflect and disclose attributed income and gains in Annual Returns of Income and financial statements

Presenter

Piet Nel - CA (SA)

Piet specializes in taxation and is currently the Project Director of Professional Development (Tax) at SAICA. He previously held the position of Project Director for Tax at SAICA for three years. Prior to rejoining SAICA, Piet worked in tax consulting and tax dispute resolution. He is also an accounting member of the Tax Court.

Piet is a visiting adjunct professor at Wits University and has lectured in tax at the postgraduate level at the University of Pretoria and UNISA.

He served as a member of SAICA’s National Tax Committee and remains actively involved in the development of South African tax legislation through commentary on proposed laws.

With over three decades of experience, Piet has presented numerous seminars and workshops for tax practitioners. He frequently appears on radio and TV and regularly publishes articles on tax topics.

Additionally, Piet contributes to the profession as a member of SAICA’s Examination Committee, helping to set the entrance examination for CA (SA).

During her position as Tax Manager and heading up the entire tax practice, she completed her HDip Tax and ADip Tax (Advanced Diploma in Tax Procedural Law) through Thomas Jefferson School of Law and passed both with distinction. She started running her own tax practice in September 2016 specialising in dispute resolution, trusts and SARS compliance.

CPD

Attending these webinars and the successful completion of the online assessment will secure a certificate of completion for 2 hours of Tax CPD.

Event Investment

Free for Tax Practitioner, Tax Accountant CPD subscribers and Practice Packages. Not a CPD subscriber yet? Click here to register now.

• Regular price:  R460.00
• Special rate for SAIT members:  R368.00
• Group booking discounts available when you register for a group.

Payments and cancellations

• All payments must be made by EFT or by credit card, at least 3 working days before commencement of an event.
• Kindly note that should payment not be received 2 days after the event, legal action will be taken
• Proof of payment will be requested at registration, if payment does not reflect on Tax faculty’s bank account.
• Only written notice of cancellation will be recognized.
• Conditions:
  • If the cancellation occurs more than 4 working days prior to the event no cancellation fee will be charged.
  • If the cancellation occurs less than 4 working days prior to the event a 100% cancellation fee will apply.
• Delegates who book and fail to attend will be liable for the full event fee.
• Tax faculty’s liability in the case of an event being cancelled will be limited to a refund or credit of the event fee.
• Please click here for the full terms and conditions.