Executive summary

South Africa’s tax-deductible allowance for future expenditure on contracts (i.e., section 24C of the Income Tax Act No 58 of 1962 (the Act)) has again come under scrutiny during the delivery of the Constitutional Court Judgment in Big G Restaurants (Pty) Ltd v CSARS on 21 July 2020.

The purpose of section 24C is to address the anomaly that arises when income is…