Executive summarySouth 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 received under a contract in one year and the expenditure is incurred to perform under that contract in a subsequent year of assessment. The section 24C allowance provides tax relief to the taxpayer where a mismatch between income and expenditure occurs in...