The Supreme Court of Appeal of South Africa gave its decision on 8 May 2012 in the case of The Commissioner for the South African Revenue Service v. Tradehold Ltd (Case No. 132/11) [2012] ZASCA 61). Details of the decision are summarized below. (a) Facts. This was an appeal by the South African Revenue Service (SARS) against the decision of the Cape Town Tax Court. The respondent, Tradehold Limited (Tradehold), is an investment holding company incorporated in South Africa and listed on the Johannesburg Stock Exchange. Its main asset comprised of shares in Tradegro Holdings Limited (Tradegro), a company incorporated in Guernsey....